Clifford Chance

Clarifications regarding transfer pricing rules for intra-group financing transactions

12 April 2011

On 8 April 2011 the Luxembourg direct tax authorities issued Circular L.I.R. 164/2 bis (Circular Bis), which clarifies the conditions for application of their previous circular dated 28 January 2011 (the Initial Circular) relating to the tax treatment of intra-group financing transactions (see Client briefing January 2011). This development can be seen in the light of the desire of the Luxembourg tax authorities to reiterate the alignment of their APA practice with OECD transfer pricing principles.

 

Clifford Chance has prepared a briefing paper outlining these clarifications.

Download PDF