Account 115 and Luxembourg Parent-Subsidiary Exemption

On 31 March 2022, the Luxembourg Administrative Court ruled that account 115 contributions are not to be taken into account to determine the minimum acquisition value of a participation for the purposes of the Luxembourg parent-subsidiary exemption.

Read our full alert to learn more about:

  • The legal context: the Luxembourg parent-subsidiary regime;
  • The background of the case;
  • The position defended by the Parent Company;
  • The decision of the Court; and
  • The recommendations and next steps.