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By Emilien LEBAS, Partner, International Tax, Tax controversy dispute resolution leader Valentine PLATEAU, Manager, International Tax, KPMG Luxembourg
On 17 July 2024, the Luxembourg administrative court of appeal (the Administrative Court) (Cour administrative, 17 juillet 2024, n°50199C) issued a decision in which it took position on whether, and under which circumstances, convertible bonds could be valued at fair market value (FMV) for the computation of unitary value based on §14 of the Valuation Law (Bewertungsgesetz – “BewG”).
Case summary
In the case under review, on 1 February 2019 the Luxembourg tax authorities challenged the unitary values, and consequently the corresponding net wealth...
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