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By Emilien LEBAS, Partner, Head of International Tax, Tax controversy dispute resolution leader Valentine PLATEAU, Manager, International Tax, KPMG Luxembourg
On 18 December 2025, the Luxembourg administrative Court of Appeal (Cour administrative, 18 décembre 2025, n°52666C) (the “Administrative Court” or the “Court”) had the opportunity to review the position taken earlier that year by the Luxembourg administrative Tribunal (the “Administrative Tribunal” or “Tribunal”) (Tribunal administratif, 26 février 2025, n°47358) concerning the non-deductibility for Luxembourg direct tax purposes of interest expenses in connection with a loan granted to a taxpayer by an affiliated undertaking.
Summary of the case
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