163 results found

The two most influential people in international tax matters are the head of Tax Affairs at the OECD, Pascal Saint-Amans, and the EU Tax Commissioner, Pierre Moscovici.

The Apple case has shot EU state aid rules into the headlines.

Some time has now passed since the new transfer pricing circular for financing companies in Luxembourg ("Circular") was passed, and I would like to share with you three insights that I have gained...

Explore the most recent CJEU Advocate General opinions on valuing intragroup services and handling TP adjustments for VAT purposes.

The asset management industry in the United Kingdom is the one of the biggest in the world, while Luxembourg is often cited as a key jurisdiction ...

On 14 December 2023, the CJEU decided in favour of Amazon in State aid case C-457/21 P by confirming the General Court's conclusion that the Commission did not demonstrate that Luxembourg granted a selective advantage to Amazon.

At its core, the case concerns a Luxembourg holding company (the “Company”) that had contractually agreed to bear the credit risk on loans managed by a related entity’s permanent establishment located in Luxembourg (the “Branch”), without disclosing this arrangement to the Luxembourg tax authorities (the “LTA”) and without receiving any compensation.

On 27 December, 2016 the Luxembourg Tax Authorities issued the new Circular LIR n°56/1-56bis/1 on the tax treatment of entities engaged in intra-group financing activities.

On 30 March 2020, the Luxembourg government filed Bill of law No 7547 implementing certain guidelines approved by the Council of the EU on 5 December 2019 related...

The recent CJEU decision in Arcomet provides binding guidance on the VAT treatment of TP adjustments on intragroup services calculated using an OECD-recommended method.

The Luxembourg VAT Authorities released Circular n°790 in which they have provided some clarifications on the taxable basis to be considered in transactions involving related parties.

Pillar Two is a groundbreaking international tax framework that imposes a 15% minimum taxation to multinational enterprises in each country where they operate.

After many years of reforms encouraged by the OECD's BEPS Action plan, it seems as if Luxembourg is now on the home stretch of the BEPS reform marathon

On 28 March 2023, a new draft law was released in order to simplify and modernise the rules governing the direct tax procedure in Luxembourg.

Le 7 juin 2016, la Commission européenne a publié la version non confidentielle de sa décision d'ouvrir une enquête formelle visant à établir si le ruling/rescrit fiscal accordé par l'administration fiscale luxembourgeoise ...

Advocate-General Kokott has advised the European Court about the VAT aspects of a transfer pricing adjustment for intra-group supplies of goods. She concluded that such transfer pricing adjustments may fall within...

On 28 January 2021, the Luxembourg parliament approved bill of law n°7547 implementing measures concerning the non-tax-deductibility ...