163 results found

There is no doubt that the recent implementation of the new tariffs in the first half of the year on global imports to and exports from the United States has significantly...

The first official guidance on the interest deduction limitation rules provided by Article 168bis of the Luxembourg Income Tax Law was published in the tax circular by the Director of Luxembourg Taxation, dated 8 January 2021.

In its decision of 22 July 2026 (case 53194C), the Luxembourg Administrative Court, the Luxembourg court of appeal in tax matters, rendered an important transfer pricing judgment concerning the application of the arm's-length principle to the restructuring of intra-group debt and the deductibility of interest expenses.

On Saturday 21 March 2020, the Luxembourg parliament passed the law implementing the Council Directive (EU) 2018/822 of 25 May 2018 ("DAC6") regarding the mandatory exchange of ...

Article 80 of the EU VAT directive provides that member states have the discretion to take measures to combat VAT fraud or evasion.

A transfer price designates the price at which goods, services, intellectual property, or financing is transferred between related parties.

On 28 January 2011, the Luxembourg direct tax authorities issued a circular (L.I.R n°164/2) (the "Circular"), which clarifies the tax treatment of Luxembourg companies that perform intra-group financing activities and sets out the framework for granting advance tax clearance concerning them.

On 15 July 2020, in the Apple case, the EU judges (General Court) concluded for the second time in less than one year that the EU Commission failed to demonstrate that by issuing a tax ruling dealing with transfer pricing matters, ...

In its decision regarding Amazon, the General Court concludes that "none of the findings set out by the Commission in the contested decision are sufficient to demonstrate the existence...

An increase in disputes between companies and tax authorities-kicking off in 2015 with the European Commission intervention in the Fiat case-has come to define the current era of corporate tax.

The Irish Revenue Commissioners ("Revenue") issued an ebrief on 4 December 2023 regarding the publication of an updated manual on section 112B of the Taxes...

Increased substance requirements, remaining compliant under BEPS-related law changes and the CRS; find out what organisations operating in Luxembourg need to know.

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 of the OECD Transfer Pricing Guidelines...

On 25 May 2018, the ECOFIN Council adopted the 6th Directive on Administrative Cooperation, commonly called DAC6, which requires so-called tax intermediaries to report certain ...

On 12 September 2023, the European Commission introduced the Transfer Pricing Directive proposal ("TP Proposal").

On 8 January 2021, the Luxembourg tax authorities issued a new Circular n°168bis/1 in order to provide guidance on the interpretation of the interest deduction limitation rules laid down in Article 168bis of the ...

The end of 2023 has been marked by the legislative elections and the formation of a new government in Luxembourg. Time has now come to provide you with a few insights on what has happened...

Our tax litigation team recently had the opportunity to assist a taxpayer in an appeal for the reversal of a decision issued by the Luxembourg tax administration that considered that the interest on a profit participating loan was excessive, ...