Luxembourg Inland Revenue (ACD) issued 260 preemptive opinions--called “advance price agreements” and “advance tax rulings”--in 2017, a number which decreased by 43% to 148 in 2018.

The figures were published in an annex to the finance ministry’s 2018 annual activity report (PDF), released on 18 April 2019.

Out of the 148 opinions issued last year, 117 were “favourable” to the taxpayer, while ACD rejected 31 requests.

The numbers declined for both types of comfort letters.

An advance price agreement is granted by national tax authorities around the world to multinational companies, and specifies how the tax office will treat transactions between different parts of the firm.

An advanced tax rulings is written confirmation of how tax law will be applied to a specific corporate or individual taxpayer’s case.

Both types of documents are generally binding for a certain number of years.

According to the European Commission, Luxembourg tax authorities issued 599 advance tax price agreements in 2016 and 145 in 2015.