Spletrequirement by foreign tax authorities of real substance for private equity and venture capital vehicles in order to benefit from the desired tax status. The required level of substance is determined primarily by the tax rules of the country(ies) where the assets are / will be located and will have to be considered on a case by case basis. Splet19. jan. 2024 · On 8 January 2024, the Luxembourg tax authorities issued the long-awaited administrative circular (the “ Circular ”) providing guidance on certain aspects of the interest deduction limitation rule (“ IDLR ”) laid down in Article 168bis of …

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