Luxembourg: 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.

Directive On Administrative Cooperation In Taxation (DAC) Recast Proposal: Key Developments

The European Commission's proposal to recast the Directive on Administrative Cooperation (DAC) represents a significant shift in tax transparency requirements, particularly targeting...

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ATOZ

The Administrative Court Of Luxembourg And The Qualification Of Interest-free Loans

Explore recent developments in Luxembourg tax law, including administrative court rulings on interest-free loans, corporate tax losses, and share premium repayments. ATOZ provides expert analysis on transfer pricing disputes, the new impatriates regime, and Pillar Two GIR filing exemptions that impact multinational corporations and investment structures.

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ATOZ

ATOZ Insights - April 2026

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.

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ATOZ

Tax In Distressed Situations Luxembourg

Instead, the general principle of substance over form applies to determine the tax classification of an instrument as debt or equity, requiring an economic and financial analysis of each transaction.

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Loyens & Loeff

WEBINAR REPLAY | Transfer Pricing In Fund Structuring

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CMS Luxembourg

VAT Treatment Of Transfer Pricing Adjustments: Advocate General Brings Clarity To A Complex Area

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Arendt & Medernach

WEBINAR REPLAY | How To Tackle The TP Challenges Relating To Intragroup Financing Activities?

CL

CMS Luxembourg

Advocate-General Sheds Light On VAT Implications Of Transfer Pricing Adjustments

European Union Tax

LL

Loyens & Loeff

Luxembourg As An International Debt Issuance Hub For Brazilian Groups

LL

Loyens & Loeff

Tax Trends And Developments For MNEs In 2026

LL

Loyens & Loeff

WEBINAR REPLAY | The TP Aspects Of Intragroup Loans – Debt-to-equity Ratio – Interest Rate Determination

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CMS Luxembourg

Developments In Tariffs And Their Interaction With Transfer Pricing

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Loyens & Loeff

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

European Union Tax

LL

Loyens & Loeff

Transfer Pricing Forum – Transfer Pricing For The International Practitioner

LL

Loyens & Loeff

End Of The MiCAR Transitional Regime On 1 July 2026: Practical Impacts For VASPs And Their Customers

Luxembourg Finance

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CMS Luxembourg

Luxembourg Proposes New Tax Regime For Stock Options In Innovative Companies

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Tiberghien

AML-CTF Package: Gear Up Now

Luxembourg Government

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CMS Luxembourg

Luxembourg Tax Alert — Advocate General Recommends Dismissal Of Commission Action Concerning Luxembourg's Application Of The ATAD Interest Limitation Rules To Certain Securitisation Vehicles

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Goodwin Procter LLP

Risk-based Approach : Key Updates

Luxembourg Commercial

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CMS Luxembourg

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.

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Arendt & Medernach

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

On 17 April 2025, the Luxembourg Higher Administrative Court (Cour administrative), delivered its long awaited decision on case n° 50.602C pertaining to the qualification of interest free loans under Luxembourg tax law and the existence of a permanent establishment in a treaty jurisdiction.

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BSP

Luxembourg Government Releases Draft Law Implementing DAC8

On 24 July 2025, the Luxembourg government released a draft law aimed at implementing Council Directive 2023/2226 dated 17 October 2023, the so-called "DAC8", amending Directive 2011/16/EU...

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ATOZ

European Court Further Clarifies Interplay Between VAT And Transfer Pricing

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

European Union Tax

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Loyens & Loeff

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

European Union Tax

LL

Loyens & Loeff

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

AM

Arendt & Medernach

Advocate-General: TP Adjustments May Have VAT Implications

European Union Tax

LL

Loyens & Loeff

Tax Update In Luxembourg Regarding Interest Rates For Shareholder Current Accounts

GP

Goodwin Procter LLP

Welcome Clarification On Dutch Transfer Pricing Mismatch Legislation Scope In Respect Of Deemed Dividend Distribution Due To Non-arm's Length Transaction Between Foreign Subsidiaries

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Loyens & Loeff

EU Tax Directives #1: Introduction To EU Tax Directives – New York Office Snippet

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Loyens & Loeff

New Luxembourg Tax Circular On Interest Rates For Shareholder Current Accounts

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Arendt & Medernach

Us Fund Managers Raising Capital In Europe: Mind The Luxembourg Reverse Hybrid Rules – New York Office Snippet

LL

Loyens & Loeff

ATOZ Insights - November 2024

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ATOZ

Commission Closes State Aid Investigations Into Fiat, Amazon And Starbucks Tax Rulings

European Union Tax

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ELVINGER HOSS PRUSSEN, société anonyme

New Luxembourg Tax Circular On Interest Rates For Shareholder Current Accounts

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

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Arendt & Medernach

Us Fund Managers Raising Capital In Europe: Mind The Luxembourg Reverse Hybrid Rules – New York Office Snippet

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.

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Loyens & Loeff

ATOZ Insights - November 2024

2024 Luxembourg ongoing initiatives in tax matters – State of play...

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ATOZ

Commission Closes State Aid Investigations Into Fiat, Amazon And Starbucks Tax Rulings

The European Commission (the "Commission") has closed three in-depth State aid investigations into transfer pricing tax rulings granted by Luxembourg to Fiat and Amazon...

European Union Tax

EH

ELVINGER HOSS PRUSSEN, société anonyme

Tax Trends And Developments For MNEs In 2025

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Loyens & Loeff

EU Commission's Initiatives In Direct Tax Matters: State Of Play

Ongoing direct tax initiatives of the European Commission have not really evolved over the past 4 months and why we see more and more EU national Parliaments taking a very critical stand on the reforms...

European Union Tax

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ATOZ

Exploring The Synergy: VAT And Transfer Pricing

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).

European Union Tax

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Arendt & Medernach

Luxembourg Transfer Pricing Considerations For In-house AIFMs – New York Office Snippet

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

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Loyens & Loeff

Pillar Two: A New Era Of International Taxation

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

European Union Tax

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Loyens & Loeff

Amazon And Fiat Rulings Define New, More Contentious Tax Era

European Union Tax

LL

Loyens & Loeff

Tax Update - December 2023

European Union Tax

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Matheson

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

European Union Tax

AM

Arendt & Medernach

Soparfi : The Luxembourg Holding And Finance Company - Update January 2024

European Union Tax

EH

ELVINGER HOSS PRUSSEN, société anonyme

ECJ Rules In Favour Of Amazon In State Aid Case

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BSP

New Protocol To The Luxembourg/Germany Double Tax Treaty Applicable As From 2024

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ATOZ

The Amazon State Aid Case: CJEU Rules That The EU Commission's Decision Infringes EU Law

European Union Tax

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ATOZ

European Union Tax

EH

ELVINGER HOSS PRUSSEN, société anonyme

EU Tax Alert 203

European Union Tax

LL

Loyens & Loeff

ATOZ Insights - December 2023

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ATOZ

EU Top Court Confirms Amazon And Luxembourg Win In EU State Aid Case

European Union Tax

LL

Loyens & Loeff

Long Awaited Local File / Master File Regulation In Luxembourg

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CMS Luxembourg

CJEU Sides With ENGIE And Luxembourg In Tax State Aid Case

European Union Tax

LL

Loyens & Loeff

Luxembourg Confirms Debt Treatment Of Interest-Free Loan

Luxembourg Finance

LL

Loyens & Loeff

Luxembourg Pillar Two Bill Of Law Amended To Introduce Additional OECD Guidance

European Union Tax

LL

Loyens & Loeff

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Latest Videos

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Développement Durable : Les Enjeux Juridiques Et Fiscaux (Video)

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Grant Thornton Société d’Avocats

Transfer Pricing: Takeaways From Recent Case Law (Video)

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Arendt & Medernach

Tax Webcast March 2018 (Video)

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Deloitte Cyprus

Transfer Pricing in Luxembourg

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Arendt & Medernach

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

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Arendt & Medernach

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