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.
Maples Group