Historically, many companies in Luxembourg were expected to maintain a 85/15 debt-to-equity ratio for financing the acquisition of subsidiaries. However, with the introduction of Chapter X of the OECD Transfer pricing Guidelines in 2020, standards might change in a near future.
On the other hand, payments under debt instruments are normally tax deductible and deduction limitations have been a hot topic in Luxembourg for many years. Following the implementation of ATAD 1, their level of complexity has increased proportionate to the growing confusion in businesses.
Is your company at risk to be impacted?
Join us for a Tax and TP breakfast where we will discuss:
- Intra-group financing activity vs. shareholding activity in a Transfer Pricing context
- Debt-to-equity ratio, other supportive ratios and methodologies
- Interest-deduction limitation rules under ATAD 1
- Recapture rules
- Practical cases
- Q&A session
- 8.00 AM : Welcome – coffee & breakfast
- 8.30 – 9.30 AM : Presentation
- 9.30 – 9.45 AM : Q&A
Free participation, breakfast included – Registration required.
This event takes place as a CovidCheck Event!
Jean-Nicolas Bourtembourg is Partner, Head of Tax & Transfer Pricing at Grant Thornton Luxembourg. He assists clients on all kinds of tax matters including the tax aspects of structured finance, tax advices in the context of M&A, real estate, private equity and venture capital transactions...
Manager, Transfer Pricing
Senior, Tax Advisor
13 rue de Bitbourg, L-1273, Luxembourg