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On 11 May 2021, the Luxembourg Administrative Tribunal ruled on whether contributions to "account 115" have to be taken into account when computing the acquisition price of a shareholding for the application of the participation exemption regime.

On 28 January 2011, the Luxembourg direct tax authorities issued a circular (L.I.R n°164/2) (the "Circular"), which clarifies the tax treatment of Luxembourg companies that perform intra-group financing activities and sets out the framework for granting advance tax clearance concerning them.