Abstract
In this note, the authors discuss two administrative circulars on the tax treatment of intra-group financing transactions issued by the Luxembourg tax authorities in January and April 2011, which clarify the application of the OECD Transfer Pricing Guidelines to debt-funded intra-group financing activities, list conditions that need to be met in order for a taxpayer to obtain a binding advance pricing agreement and provide for a grandfathering period for existing structures.
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