Market Intelligence

The Dutch Supreme Court has clarified a critical aspect of tax law regarding burden of proof when taxpayers file returns with substantive errors. This ruling determines when and how extensively the burden shifts to taxpayers to demonstrate the incorrectness of tax assessments, with potentially far-reaching implications for complex disputes involving transfer pricing and other intricate tax matters.

A German municipality's purchase of sewage sludge services from an Austrian supplier has sparked a critical VAT question now before the CJEU: can a highly automated, remotely monitored plant constitute a fixed establishment under EU VAT rules? The German Federal Fiscal Court seeks clarity on whether unmanned technical resources, combined with remote oversight and subcontractor staff, create sufficient local presence to shift reverse charge liability.

Malta's Budget for 2027, presented to Parliament on 26 October 2026, contains a set of measures that change the position of third-country nationals living in Malta from January 2027. It specifies no change to the Malta Permanent Residence Programme (MPRP), the Nomad Residence Permit, the special tax status programmes or the personal income tax rates.

Panama and Vietnam have been removed from the EU's Blacklist of non-cooperative tax jurisdictions, a change that directly impacts Luxembourg taxpayers through interest and royalty deductibility rules, tax-return reporting requirements, and mandatory disclosure obligations under DAC6. ATOZ's tax experts examine how these removals affect compliance and reporting for businesses operating in Luxembourg.

Luxembourg's proposed 2027 budget law introduces significant corporate tax reforms, including a 1% reduction in corporate income tax rates that would lower the maximum aggregate tax burden in Luxembourg City to 22.80%. The Bill also extends the holding period for speculative gains on movable assets from six to twelve months and eliminates the 17-year limit on tax loss carryforwards, measures designed to enhance Luxembourg's competitiveness while encouraging longer-term investment strategies.

Luxembourg's draft budget for 2027 introduces significant tax reforms affecting businesses, investors, and employers, including a corporate income tax rate reduction, unlimited loss carryforwards, and enhanced investment credits for digital and green initiatives. The proposed measures also modify capital gains rules, residential investment deductions, and streamline employer reporting obligations for impatriate and profit-sharing regimes.