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Luxembourg Court

|Treaty Development|Luxembourg-France
Luxembourg-France
decision on taxation of capital gains derived from merger of French SCI with Luxembourg company

The Court of Appeals of Luxembourg confirmed on 10 January 2006 (Case No 20307/C) an earlier decision of the Administrative Court of 20 July 2005 (Case No 19280). The Court held that capital gains derived by a Luxembourg company from the merger of a wholly-owned French SCI with another French company, in exchange for shares, are taxable in Luxembourg under Luxembourg domestic la…

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