This regime allows for compensation of losses suffered by any integrated company with profits from other companies within the group.
Several conditions should be met. These include:
The consolidated companies have to be fully taxable resident capital companies in Luxembourg.
That the regime applies for an initial minimal period of five financial years.
Companies must have the same date for closing their accounting financial years.
As the regime is not mandatory, a written application has to be made to the tax authorities.
Each company of the group files an individual tax return (for corporate income tax and commercial income tax - not for wealth tax).
The mother company files a consolidated statement.
The carried forward losses, made prior to integration, cannot be used against future consolidated profits.
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