On December 27 2016, the Luxembourg Tax Authorities (LTA) published a circular, L.I.R. no 56/1 – 56bis/1 (Circular) designed to position the seminal principles of the OCED TP Guidelines (i.e. the arm’s-length principle, comparability and substance over form) as the framework of reference when establishing the capital structures and the remunerations of financing vehicles in Luxembourg. With an effective date of January 1 2017, the Circular has left virtually no time for taxpayers to adjust to this new paradigm while many questions regarding the scope, implementation and implications remain unanswered.
February 03 2017