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Luxembourg further clarifies transfer pricing rules

April 20, 2011

The tax authorities in Luxembourg issued Circular LIR 164/2 bis, on April 8, which serves to clarify transfer pricing rules for resident taxpayers.

Before the initial circular LIR 164/2, no transfer pricing legislation had been formalised. Given that the circular applies to all entities undertaking intra-group financing transactions and Luxembourg is a popular location for intermediary financing activities, the clarification on the guidance applies to a significant number of taxpayers.

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