A capital contribution without issuance of shares does not increase the acquisition price
11 April 2022
On 31 March 2022, the Luxembourg Higher Administrative Court confirmed the judgement of the Luxembourg Lower Administrative Court dated 11 May 2021, which ruled that capital contributions made into a Luxembourg company without issuance of shares (also known as “115 account contributions”) are not part of the acquisition price to be considered for application of the parent subsidiary withholding tax exemption.
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