163 results found

Loyens & Loeff New York regularly posts ‘Snippets' on a range of EU tax and legal topics. This Snippet describes Luxembourg transfer pricing (‘TP')...

The preferred fund vehicle for US fund managers (𝐔𝐒𝐅𝐌𝐬) raising capital in the EU is usually a Luxembourg special limited partnership (𝐒𝐂𝐒𝐩) qualifying as an alternative investment fund.

ATOZ provides comprehensive tax and legal advisory services with a focus on personalized client relationships and pragmatic solutions. The firm publishes regular insights covering international tax developments, regulatory updates, and business guidance across multiple jurisdictions including Luxembourg, UAE, and EU member states.

On 29 January 2025, the Luxembourg tax authorities issued Circular L.I.R. n° 164/1, replacing the previous circular dated 23 March 1998.

On 18 December 2020, the OECD published its much-anticipated "Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic".

Transfer pricing remains a primary focus of the international tax community. International efforts led primarily by the Organisation for Economic Co-operation and Development...

Tariffs are by no means a new phenomenon, but recent developments have had a profound impact on global supply chains and international trade. From the US tariff waves introduced under the Trump administration...

The OECD released its public discussion draft on Action Point 4 of the Action Plan on Base Erosion and Profit Shifting (hereafter "BEPS") concerning interest deductions and other financial payments.

There are significant changes to the guidance in respect of the profit split method, hard-to-value intangibles (HTVI) and financial transactions.

On 29 January 2025, the Luxembourg tax authorities published Circular L.I.R. n° 164/1 (Circular), which replaces the previous circular L.I.R. n° 164/1, dated 23 March 1998.

Transfer pricing has become the hot topic in Luxembourg taxation over the last few years in an environment that relies increasingly less on tax rulings.

On 5 December 2023, the Court of Justice of the European Union (CJEU) annulled the General Court's judgment in the ENGIE State aid case.

In a ruling of 3 July, the European Court offers further clarity on how intra-group transfer pricing arrangements should be treated for VAT.

VAT and transfer pricing have always had an ambiguous relationship, which has led to uncertainty for businesses and stakeholders with regard to what are known as the Transfer Pricing Adjustments (TP Adjustments).

Simply put, at present we have an EU legal framework that identifies any distinction in a tax system as being potentially illegal state aid.

As usual, the weeks prior to the summer break are a little bit hectic.

On 30 March 2020, the Luxembourg finance minister introduced a bill ("the bill") aimed at implementing European Union (EU) recommended preventive measures.