Revamping of the Luxembourg transfer pricing rules applicable to intra-group financing transactions

January 03, 2017

The Luxembourg direct administration published Circular L.I.R. n° 56/1 – 56bis/1 applicable to companies carrying out intra-group financing transactions (the Circular) on 27 December 2016. The Circular has replaced two existing circulars published in 2011 (the 2011 Circulars) and follows the introduction of the new article 56 bis of the Luxembourg income tax law on the application of the arm’s length principle.

The revamping of the Circular has been made in coordination with the European Commission and enables Luxembourg to adapt its legal framework to take into account the latest international and European tax developments. Other Member States will most likely need to adjust their internal legislation in the same manner within the coming months.

Read "Revamping of the Luxembourg transfer pricing rules applicable to intra-group financing transactions."