The Luxembourg Administrative Court issued a judgment on 22 July 2026 in Case No. 53194C concerning the application of the arm's-length principle to the restructuring of intra-group debt and the deductibility of related interest expenses. The Court ruled in favor of the taxpayer and overturned the judgment of the Administrative Tribunal. The case concerned a Luxembourg company engaged in intra-group financing that had granted a loan bearing interest at 12% to a French subsidiary in which it …