On 19 April 2007, the Luxembourg Administrative Court of Appeal gave its decision in Case No. 21979 C on the possibility to opt for group treatment for six Luxembourg subsidiaries of a Belgian parent company. Details are described below. (a) Facts. Six subsidiaries of a Belgian parent company were established in Luxembourg. One of the subsidiaries was loss-making, whereas the others were profitable. The subsidiaries requested the application of group treatment, which provides for a compensation of profits and losses. (b) Legal background. Art. 164bis of the Luxembourg Income Tax Code provides that group tax treatment is allowed if the...