European Union: Transfer Pricing

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Article
Luxembourg Court Confirms Arm’s Length Remuneration Tax Requirement For Undisclosed Intra-Group Counter-Guarantee
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.
Luxembourg Tax
MG
Maples Group
Article
Dutch Ministry Of Finance Updates Hybrid Mismatch Decree: Broader Guidance And New Practical Examples
The Dutch Ministry of Finance has issued an updated Decree providing crucial clarifications on the practical application of hybrid mismatch rules under ATAD2. These updates address key interpretative questions that have emerged in practice, particularly concerning the interaction with US tax regimes, capitalised acquisition costs, and cost-plus transfer pricing structures.
Netherlands Tax
LL
Loyens & Loeff
Article
The European Commission Adopts The Tax Simplification Package
The European Commission has adopted a comprehensive Tax Simplification Package aimed at reducing administrative burdens and enhancing competitiveness for businesses operating across the EU. This package consolidates existing tax directives and introduces significant reforms to interest limitation rules, controlled foreign company provisions, and withholding tax exemptions, while establishing new minimum standards for R&D tax treatment to align the EU more closely with major trading partners.
Ireland Tax
AC
Arthur Cox
Article
Prix De Transfert : Confirmation Du Transfert Indirect De Bénéfices Par Un Distributeur Routinier Supportant Des Charges De Valorisation De Marques Non Rémunérées
The Paris Administrative Court of Appeal examines whether a French subsidiary operating as a routine distributor with limited risks indirectly transferred profits to its Italian parent companies by bearing disproportionate rental and personnel costs that contributed to brand development and customer acquisition without receiving compensation.
France Tax
MB
Mayer Brown
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