European Union: Transfer Pricing

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

The Cyprus Holding Company: A Complete Guide To Benefits, Tax Efficiency And International Structuring

The moment a business expands across borders or an entrepreneur begins managing several ventures, the structure behind the operations becomes just as important as the business itself.

Cyprus Commercial

Nikita & Partners Limited

OECD Awards Confirm Strength Of Ireland's Competent Authority

On 31 October 2025, the OECD published its 2024 statistics on Mutual Agreement Procedures ("MAPs") and Advance Pricing Agreements ("APAs") as part of the OECD's Tax Certainty Day.

M

Matheson

European Commission Publishes Second Evaluation Of The Directive On Administrative Cooperation In Taxation (DAC)

On 19 November 2025, the European Commission published its second evaluation of Council Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC)...

Netherlands Tax

LL

Loyens & Loeff

How The Cyprus IP Box Works In Practice Under The OECD "Modified Nexus" Approach

To benefit, the IP owner must also meet the nexus requirement — i.e., the IP income must come from its own R&D activities (or outsourced to unrelated parties) that created the IP.

CA

CYAUSE Audit Services Ltd

DEMPE In Domestic Transfer Pricing Practice: Insights From The Netherlands, Belgium And Luxembourg

European Union Tax

LL

Loyens & Loeff

Transfer Pricing Adjustments May Constitute The Consideration For A Taxable Supply Of Services (ECJ Case 726/23)

GGI Global Alliance

2024 OECD MAP Statistics: Key Trends In MAP And APAS As Ireland Recognised As Most Improved Jurisdiction For APAS

AG

A&L Goodbody LLP

Transfer Pricing Forum – Transfer Pricing For The International Practitioner

LL

Loyens & Loeff

Italian Supreme Court Clarifies Zero Balance Cash Pooling In Cross-border Cases

GGI Global Alliance

EU VAT Quarterly Wrap-up –– Q3 2025

Netherlands Tax

AM

Alvarez & Marsal

The Taxation Of Royalty Income In Portugal: A Look At The Patent Box Regime

DG

Dixcart Group Limited

Transfer Pricing And Customs Valuation: Navigating Germany's Regulatory Landscape In 2025

N

NERA

German TP Update: Amended Guidance On International Mutual Agreement And Arbitration Procedures

AM

Alvarez & Marsal

EU Tax Alert 212

European Union Tax

LL

Loyens & Loeff

Ep1 - Planning Ahead - The Planning And Development Act 2024 (Podcast)

Ireland Real Estate

WF

William Fry

Podcast Series Episode 8: Multiple-Vote Share Structures Directive

BL

Bernitsas Law

Podcast Episode 1: Cross-Border Disputes In The EU: The Cyprus Advantage (Podcast)

Cyprus Technology

A|

AGPLAW | A.G. Paphitis & Co. LLC

British Passport Holders - Relocating To Cyprus (Video)

Cyprus Immigration

CA

CYAUSE Audit Services Ltd

The Malta Nomad Residence Permit (NRP) (Video)

Malta Immigration

CG

CSB Group

Les régularisations de prix de transfert sont susceptibles d'être assimilées à des prestations de services onéreuses relevant de la TVA

En matière de TVA, la Cour de justice de l'Union européenne juge que la rémunération de services intragroupe, versée par une filiale à sa société mère en application d'un contrat de prestations détaillées...

MB

Mayer Brown

Transfer Pricing Adjustments Within Multinational Groups May Be Subject To VAT: Milestone Decision By Court Of Justice Of The EU

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.

AM

Arendt & Medernach

European Court: Contractually Agreed TP Adjustments May Have VAT Implications

The European Court has ruled that transfer pricing adjustments may be subject to VAT when they are contractually stipulated in an intra-group agreement.

European Union Tax

LL

Loyens & Loeff

Clarification On The Interaction Between Dutch Transfer Pricing Mismatch Rules And Foreign Participation Exemption Regimes

The Dutch tax authorities published a new Knowledge Group (KG) position clarifying that the Dutch transfer pricing mismatch rules do not apply when a foreign regime that effectively functions as an objective exemption applies to the transfer of a participation.

Netherlands Tax

LL

Loyens & Loeff

Landmark Decision On Start-Up Loss Allocation And Substance-Over-Form In Transfer Pricing: Key Insights For Transfer Pricing And Legal Practitioners

AM

Alvarez & Marsal

Landmark Decision On Qualification Of Financial Instruments & Non-recognition Of A Foreign Permanent Establishment

B

BSP

Cyprus Tightens Transfer Pricing Documentation Rules: A New Compliance Era Begins

S

S&A

Corporate Tax 2025 – Cyprus

PL

Patrikios Legal

Luxembourg Government Releases Draft Law Implementing DAC8

A

ATOZ

Transfer Pricing In Transition? A Review Of The Tax Court's Decision In Facebook's Transfer Pricing Case In Light Of Medtronic v. Commissioner

TC

Thompson Coburn LLP

Overview Of The BMF Instruction Sheet On Cross-Border Audit Cooperation

AM

Alvarez & Marsal

BFH: A Permanent Establishment Is Not An Employer Under Tax Convention Law

FG

Flick Gocke Schaumburg

An Overview Of The EU Public Country-by-country Reporting Rules

Netherlands Tax

LL

Loyens & Loeff

Spain Shakes Up VAT Standards: Local Branches Can Be Treated As Separate Taxable Persons Outside A Vat Grouping – Impact On Financial And Insurance Industries

European Union Tax

AM

Alvarez & Marsal

Overview Of The BMF Instruction Sheet On Cross-Border Audit Cooperation

German Federal Ministry of Finance (BMF) recently released an instruction sheet on cross-border audit cooperation with tax administrations of other countries (dated May 15, 2025).

AM

Alvarez & Marsal

BFH: A Permanent Establishment Is Not An Employer Under Tax Convention Law

In its decisions of 12 December 2024 (VI R 25/22, VI R 26/22 and VI R 27/22) published on 17 April 2025, the Federal Tax Court (Bundesfinanzhof – BFH) dealt with the classification of a foreign permanent establishment as an employer under tax convention law.

FG

Flick Gocke Schaumburg

An Overview Of The EU Public Country-by-country Reporting Rules

The European Union (EU) has long been at the forefront of furthering corporate transparency and accountability.

Netherlands Tax

LL

Loyens & Loeff

Spain Shakes Up VAT Standards: Local Branches Can Be Treated As Separate Taxable Persons Outside A Vat Grouping – Impact On Financial And Insurance Industries

The Spanish Tax Authorities (STA) have interpreted EU VAT law to argue that internal flows between a head office and its foreign branches...

European Union Tax

AM

Alvarez & Marsal

European Court Further Clarifies Interplay Between VAT And Transfer Pricing

European Union Tax

LL

Loyens & Loeff

Country-By-Country Reporting (CbCR): What You Need To Know

With tax authorities increasing their focus on transparency, Country-by-Country Reporting (CbCR) has become a key requirement for multinational enterprises (MNEs).

BD

BDO Malta

Transfer Pricing Documentation

Transfer pricing regulations are critical for ensuring that multinational enterprises (MNEs) comply with tax laws in various jurisdictions.

BD

BDO Malta

Transfer Pricing: Low Value-Adding Services (LVAS)

This article examines the specifics of LVAS in the context of transfer pricing regulations.

BD

BDO Malta

How Advisory Firms Are Using Digital Twins To Stress-Test Cross-Border Corporate Structures

As multinational companies face increasingly complex tax rules, economic substance requirements, and cross-border employment challenges, advisory firms are adopting digital twin models...

E

Eurofast

Transfer Pricing For Intragroup Financing: Aligning Terms With Commercial Reality

BD

BDO Malta

Key Insights From Irish Revenue's 2024 Annual Report

M

Matheson

The Supreme Court Rules Entirely In Favour Of EET Group A/S In Landmark Transfer Pricing Case

Denmark Litigation

P

Plesner

Changes In Safe Harbour For Loans: Poland's Transfer Pricing In 2025

P

Penteris

Transfer Pricing: A Practical Guide For Growing Groups

BD

BDO Malta

EU Tax Alert 210

European Union Tax

LL

Loyens & Loeff

Transfer Pricing: What Is A Local File?

BD

BDO Malta

Transfer Pricing Master File: Requirements And Best Practices

BD

BDO Malta

Customs Duties In Transition: Why Companies Should Review Their Customs Valuations And Transfer Pricing Policies Now

Czech Republic Tax

K

Kinstellar

An Attractive Destination For IP Holding Companies

Worldwide Commercial

DG

Dixcart Group Limited

EU Tax Directives #5: Proposed EU Transfer Pricing Directive – New York Office Snippet

European Union Tax

LL

Loyens & Loeff

Notional Interest Deduction (NID)

K

Kinanis LLC

Transfer Pricing Rules In The UAE

K

Kinanis LLC

Transfer Pricing Adjustments And VAT For Multinational Groups: Latest CJEU Developments

AM

Arendt & Medernach

Corporate Tax 2025 - Ireland

MG

Maples Group

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Latest Videos

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Tax 2024: What To Expect - Discover The Recordings Of The Webinar Series

AM

Arendt & Medernach

Développement Durable : Les Enjeux Juridiques Et Fiscaux (Video)

GT

Grant Thornton Société d’Avocats

Tax Webcast March 2018 (Video)

DC

Deloitte Cyprus

Transfer Pricing In A Post BEPS World, With Alain Goebel At AFLF 2017 (Video)

AM

Arendt & Medernach

Transfer Pricing - Is Your Pricing Still Arm's Length? (Video)

AM

Arendt & Medernach

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