New Circular on arm’s length interest rates for shareholder's current accounts
New Circular on arm’s length interest rates for shareholder's current accounts
On 29 January 2025, Luxembourg Tax Administration (“LTA”) issued a new Circular L.I.R. 164/1 (“Circular”), which replaces Circular L.I.R. of 23 March 1998. The Circular brings clarifications on the application of the arm’s length principle to determine interest rates applicable on current accounts of partners or shareholders of a Luxembourg company subject to corporate income tax.