Luxembourg: Higher Administrative Court Endorses Distressed Debt Concessions (Case 53194C)

The Luxembourg Higher Administrative Court (Cour administrative, No. 53194C) issued a key tax and restructuring judgment regarding intra-group debt. Reversing a tax authority assessment, the Court held that partial waivers of accrued interest or debt concessions agreed during financial distress comply with the arm’s-length principle if an independent lender would grant similar terms to avoid borrower insolvency and maximise overall recovery.

Luxembourg: Higher Administrative Court Endorses Distressed Debt Concessions (Case 53194C)
Hayden Morgan 7 September 2026
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