The other day our corporate member Loyens & Loeff published long awaited news coming out of the Luxembourg tax authorities.
On 8 January 2021, the Luxembourg tax authorities published circular LIR 168bis/1 on the interpretation of the interest deduction limitation rule, which is applicable as from tax years starting on or after 1 January 2019.
The long-awaited guidance notably clarifies the notion of borrowing costs and the grandfathering rule for loans predating 17 June 2016.
Taxpayers should review their positions taken in respect of the application of the interest deduction limitation rule in light of this new guidance.