Tax update – Luxembourg participation exemption regime
A contribution to account 115 (i.e. a capital contribution not remunerated by shares) cannot be taken into account in order to determine the acquisition price of a participation in the share capital of a Luxembourg resident company in order to check if it is in line with the threshold of EUR 1.2 million foreseen for the parent-subsidiary withholding tax exemption, such is the decision of the highest administrative court in Luxembourg in its judgment of March 31, 2022. Read more here
A contribution to account 115 (i.e. a capital contribution not remunerated by shares) cannot be taken into account in order to determine the acquisition price of a participation in the share capital of a Luxembourg resident company in order to check if it is in line with the threshold of EUR 1.2 million foreseen for the parent-subsidiary withholding tax exemption, such is the decision of the highest administrative court in Luxembourg in its judgment of March 31, 2022. Read more here
