Offshore

Subscribe

Insights from offshore law firms, covering regulations, compliance, and legal strategies for international businesses, asset protection and wealth management.

Article
Luxembourg Court Confirms Arm’s Length Remuneration Tax Requirement For Undisclosed Intra-Group Counter-Guarantee
At its core, the case concerns a Luxembourg holding company (the “Company”) that had contractually agreed to bear the credit risk on loans managed by a related entity’s permanent establishment located in Luxembourg (the “Branch”), without disclosing this arrangement to the Luxembourg tax authorities (the “LTA”) and without receiving any compensation.
Luxembourg Tax
MG
Maples Group
See more