Luxembourg looking for more substance in Group Financing vehicle...

The 2017 budget law has been published on 27 December 2016 in the official gazette.

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The new article 56bis and its complement, the Circular n°56/1-56bis/1, are giving new guidance for transfer pricing on intra-group financing activities.

ADEQUATE SUBSTANCE (presence, know-how and activities) is a KEY ELEMENT under the new framework.

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This law aims at ensuring sustainability of financing vehicles in Luxembourg.

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These new measures entered into force on January 1st, 2017.