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By Dinko DINEV, Partner and Oleg TUPCHII, Senior Manager, Transfer Pricing at Deloitte Luxembourg
NdlR. : A lire ou à relire - article publié dans notre mensuel de mai 2023
For fund managers, inter-company debt has always been a preferred way to structure capital injections into Luxembourg Special Purposes Vehicles (SPVs) because it provides a fast and efficient way to move cash across the investment platform.
However, SPV debt financing must comply with anti-abuse and anti-simulation principles in Tax Adaptation Law(1) as well as debt-to-equity ratio of related party borrowers, such as transfer pricing (TP) rules. These principles also apply to companies engaged in holding activities...
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