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

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


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.


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


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

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