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Stibbe advises on the implementation of an intra-group financing structure involving a hybrid-profit participating loan

Stibbe advises on the implementation of an intra-group financing structure involving a hybrid-profit participating loan

Stibbe advises on the implementation of an intra-group financing structure involving a hybrid-profit participating loan

29.05.2009 BE law

Advising a major worldwide industrial player on the implementation of an intra-group financing structure involving a hybrid-profit participating loan that a Luxembourg holding company granted to a Belgian group company.

Our team obtained the first-of-its-kind ruling after the Belgian Ruling Commission lifted its ban on "hybrid PPL rulings" pursuant to the European Commission and the Code of Conduct Group’s dismissal of a complaint against such tax rulings.

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