163 results found

A debt-to-equity (D/E) analysis determines if the forecasted debt level and capital structure of a company meet the arm's length standard.

The last few years have seen some big changes in the corporate tax world – from ATAD1 & 2 and the EU Commission's anti-tax avoidance package to the recent US tax reform.

On 13 November, amendments to the bill of law implementing Pillar Two's "GloBE Rules" were published.

2023 was another year rich in tax developments in Luxembourg and Europe. In a difficult economic environment and a tense geopolitical context, the European institutions...

On 3 July 2018, the OECD launched a consultation on the transfer pricing of financial transactions by publishing the first draft of a new chapter…

The EU Joint Transfer Pricing Forum (JTPF) assists and advises the European Commission on transfer pricing tax matters. Recently, it issued a report on the application of the profit-split method

Over the last few years, transfer pricing and related documentation has become the hot topic in Luxembourg taxation in an evolving environment that is relying increasingly less on tax rulings

The Luxembourg government proposes to reform certain aspects of the tax assessment and tax litigation procedures

On 7 December 2016, the European Network on Debt and Development (Eurodad) released a report entitled "Survival of the Richest: Europe's role in supporting an unjust global tax system 2016" which was produced by NGOs in countries across Europe.

Le 27 décembre 2016, l'administration des contributions directes («l'ACD ») a émis une nouvelle circulaire sur le traitement fiscal des sociétés réalisant des activités de financement intra-groupe (la « Circulaire »).

On 28 March 2023, a new draft law (the "Draft Law") was presented to the Parliament which amends the Luxembourg General Tax Law ("GTL") as well as some other laws...

On 4 October 2017, the European Commission ("Commission") decided that Luxembourg had granted Amazon unauthorised State aid of about EUR 250 million...

Ongoing direct tax initiatives of the European Commission have not really evolved over the past 4 months and why we see more and more EU national Parliaments taking a very critical stand on the reforms...

The law of 21 December 2018 implements the EU Anti-Tax Avoidance Directive ("ATAD"), the aim of ATAD being to implement the BEPS (Base Erosion and Profit Shifting) ...

On 8 January 2021, the Luxembourg tax authorities (LTA) issued highly anticipated guidance with respect to the application of article 168 bis of Luxembourg ...

On 23 September 2022, the Luxembourg Administrative Tribunal (Tribunal Administratif, the "Tribunal", which is the first instance jurisdiction) held its decision (the "Decision")...

Therefore, in order to be taken into account, they must fulfil a main benefit test.