The Luxembourg Administration of Direct Tax has announced the publication of Circular L.I.R. n° 164/1 of 29 January 2025, which outlines the rules for determining interest rates on debit current accounts held by associates or shareholders of entities subject to corporate income tax. The Circular differentiates between cases where an associate/shareholder is a natural person and where an associate/shareholder is a related company. Where an associate/shareholder is a natural person, the arm's…