Arm's length principle; Hybrid financial instrument; transfer pricing; Article 9 OECD Model
Abstract :
[en] This case comment analyzes the interaction of Article 9 of the Italy-Luxembourg tax treaty with Luxembourg's domestic rules to adjust taxable profits in case of a interest-free loan.
Disciplines :
Tax law
Author, co-author :
Haslehner, Werner ; University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Law Research Unit
External co-authors :
no
Language :
English
Title :
Luxembourg: Profit Adjustments for Interest-Free Loans in Accordance with Article 9
