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.