On 16th December last year, Strelia secured an important ruling from the Luxembourg Administrative Court of Appeal, confirming enforceability of tax rulings signed before 2015, and this irrespective of the fact that financial projections had not been met, while LTA maintained that such constituted an “inadequate presentation of the facts”.

The same decision also takes a hard position on shareholder’s accounts, recharacterised as (taxable) hidden distribution. Such recent case-law should entice many taxpayers to revise similar arrangements whereby funds are borrowed by a shareholder of a Luxembourg resident company.

Click here to read the ruling : https://ja.public.lu/45001-50000/46136C.pdf