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Does the tax audit of a Luxembourgish financing structure only focus on the interest rate of the loans ?
What are the key elements of a Tax audit of a Luxembourgish financing structure? Is it sufficient to apply arm's length interest rates to the loans to avoid a tax assessment by the Luxembourgish tax administration?
Should my Luxembourgish company order a Transfer Pricing report for its current loans or receivables?
Is it financially better to run the risk of a tax audit or to order a TP report? Can we mitigate the risks by changing the current structure? To which extent are the Transfer Pricing rules applicable if the other companies are resident in Luxembourg?
