Luxembourg: Transfer Pricing

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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.

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Maples Group

Luxembourg Administrative Court Confirms Arm’s-Length Nature Of Debt Restructuring

In its decision of 22 July 2026 (case 53194C), the Luxembourg Administrative Court, the Luxembourg court of appeal in tax matters, rendered an important transfer pricing judgment concerning the application of the arm's-length principle to the restructuring of intra-group debt and the deductibility of interest expenses.

LL

Loyens & Loeff

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

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ATOZ

Tax In Distressed Situations Luxembourg

LL

Loyens & Loeff

WEBINAR REPLAY | Transfer Pricing In Fund Structuring

CL

CMS Luxembourg

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

AM

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

CL

CMS Luxembourg

Developments In Tariffs And Their Interaction With Transfer Pricing

LL

Loyens & Loeff

Proposed Modernization Of The Luxembourg Securitisation Legal Framework

Luxembourg Finance

TA

Tiberghien

Abusive DSARs After Brillen Rottler And The EDPB’s VRT/NOYB Decision: Relief For Controllers Or False Hope?

Luxembourg Privacy

AO

A&O Shearman

AI-Generated Content In The European Union: What The Adherence To Code Of Practice Means For Article 50 Compliance—Special Focus On Luxembourg's Financial Sector

Luxembourg Strategy

KG

K&L Gates LLP

The Boom And The Marriage Between Credit Strategies And Withdrawal Rights

Luxembourg Finance

LL

Loyens & Loeff

A Major Boost For Funded Sub-participations In Luxembourg

Luxembourg Finance

AO

A&O Shearman

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

Our Transfer Pricing colleagues have contributed to a special issue of the International Transfer Pricing Journal on the DEMPE concept in domestic Transfer Pricing practice.

European Union Tax

LL

Loyens & Loeff

Transfer Pricing Forum – Transfer Pricing For The International Practitioner

There is no doubt that the recent implementation of the new tariffs in the first half of the year on global imports to and exports from the United States has significantly...

LL

Loyens & Loeff

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

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

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ATOZ

European Court Further Clarifies Interplay Between VAT And Transfer Pricing

European Union Tax

LL

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

LL

Loyens & Loeff

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

LL

Loyens & Loeff

New Luxembourg Tax Circular On Interest Rates For Shareholder Current Accounts

AM

Arendt & Medernach

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

LL

Loyens & Loeff

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

The literal wording of the Dutch transfer pricing mismatch legislation posed uncertainty as to whether Dutch parent companies...

LL

Loyens & Loeff

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

By accession to the EU, all EU member states (𝐌𝐒) have transferred part of their sovereignty to the EU. As such, the EU can adopt directives to harmonize the laws of the MS...

LL

Loyens & Loeff

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.

AM

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.

LL

Loyens & Loeff

ATOZ Insights - November 2024

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ATOZ

10th Annual International Tax Developments Seminar - A Recap

During our 10th Annual International Tax Developments Seminar, several of our tax experts discussed the latest international tax developments.

LL

Loyens & Loeff

Tax Controversy: Trends And Developments In Luxembourg

2023 was another year rich in tax controversy, with more than 160 judgments issued in direct tax litigation cases. Whilst this is less than in 2022, several high-profile cases attracted...

LL

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

AM

Arendt & Medernach

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

LL

Loyens & Loeff

Pillar Two: A New Era Of International Taxation

European Union Tax

LL

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

M

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

CL

CMS Luxembourg

CJEU Sides With ENGIE And Luxembourg In Tax State Aid Case

European Union Tax

LL

Loyens & Loeff

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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 Luxembourg

AM

Arendt & Medernach

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

AM

Arendt & Medernach

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