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.

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

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

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

ATOZ Insights - November 2024

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ATOZ

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

European Union Tax

EH

ELVINGER HOSS PRUSSEN, société anonyme

"ESG Should Be Treated As A Systemic Challenge"

Luxembourg Real Estate

LL

Loyens & Loeff

US Fund Managers: What To Know About Luxembourg Payroll & Social Security Taxes – New York Office Snippet

LL

Loyens & Loeff

ESG Claims In Marketing Communications: What You Need To Know | Eyes On ESG (Video)

Luxembourg Commercial

AM

Arendt & Medernach

The Omnibus Endgame: EU Parliament's Anticipated Final Position On CSRD And CSDDD

European Union Commercial

LL

Loyens & Loeff

The European Commission Publishes Draft Guidance For Serious AI Incidents Under The EU AI Act

European Union Technology

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A&O Shearman

Tax Trends And Developments For MNEs In 2025

As 2024 nears its end, it is time for our annual tax update. This update focuses on the tax trends and developments we foresee for 2025 and includes tips and takeaways.

LL

Loyens & Loeff

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

Today, the European 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

Transfer Pricing Forum – Transfer Pricing For The International Practitioner

Our Luxembourg Transfer Pricing specialists have contributed to the latest edition of the Transfer Pricing Forum, published by Bloomberg Tax. This publication explores the transfer pricing implications of contract.

LL

Loyens & Loeff

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

LL

Loyens & Loeff

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

European Union Tax

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ATOZ

Exploring The Synergy: VAT And Transfer Pricing

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

Tax Update - December 2023

The Irish Revenue Commissioners ("Revenue") issued an ebrief on 4 December 2023 regarding the publication of an updated manual on section 112B of the Taxes...

European Union Tax

M

Matheson

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

2023 was another year rich in tax developments in Luxembourg and Europe. In a difficult economic environment and a tense geopolitical context, the European institutions...

European Union Tax

AM

Arendt & Medernach

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

Fully developed infrastructure of financial services and support functions...

European Union Tax

EH

ELVINGER HOSS PRUSSEN, société anonyme

ECJ Rules In Favour Of Amazon In State Aid Case

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.

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BSP

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

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ATOZ

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

On 14 December 2023, the Court of Justice of the European Union (CJEU) sided with Amazon and Luxembourg and dismissed the European Commission's appeal against a May 2021...

European Union Tax

LL

Loyens & Loeff

Long Awaited Local File / Master File Regulation In Luxembourg

On 28 March 2023, a draft bill of law aiming at modernizing and simplifying the Luxembourg General Tax Act ("GTA") was published (the "Bill").

CL

CMS Luxembourg

CJEU Sides With ENGIE And Luxembourg In Tax State Aid Case

On 5 December 2023, the Court of Justice of the European Union (CJEU) annulled the General Court's judgment in the ENGIE State aid case.

European Union Tax

LL

Loyens & Loeff

Luxembourg Confirms Debt Treatment Of Interest-Free Loan

In a final judgment rendered on 23 November 2023, the administrative court confirmed that an interest-free loan in the case at hand qualified as debt instrument for tax purposes.

Luxembourg Finance

LL

Loyens & Loeff

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

European Union Tax

LL

Loyens & Loeff

Luxembourg IP Box Tribunal's Insight On Licensing And Article 50bis LITL Exemptions

CS

Chevalier & Sciales

EU Tax Alert 202

European Union Tax

LL

Loyens & Loeff

Cross-Border Business Tax - EU Commission Proposes BEFIT, Transfer Pricing And Hot Directives

European Union Tax

AM

Arendt & Medernach

Hidden Dividend Distribution In Luxembourg: Insights From The Administrative Tribunal

CS

Chevalier & Sciales

Direct Tax Procedure: Commentary On Upcoming Amendments

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ATOZ

Corporate Tax 2023

MG

Maples Group

Outcome Statement On OECD's Pillar One

LL

Loyens & Loeff

Bill Amending Certain Tax Related Procedural Aspects

EH

ELVINGER HOSS PRUSSEN, société anonyme

Advocate General Calls On CJEU To Annul Engie And Amazon State Aid Decisions

European Union Tax

EH

ELVINGER HOSS PRUSSEN, société anonyme

Tax Controversy: Trends And Developments In Luxembourg

LL

Loyens & Loeff

2023 Global Transfer Pricing Guide

LL

Loyens & Loeff

Luxembourg Government Proposes Amendments To Tax Procedures

AM

Arendt & Medernach

Upcoming Amendments To The Luxembourg Procedure In Tax Matters

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ATOZ

Luxembourg Plans To Amend Tax Procedure And Documentation Rules

LL

Loyens & Loeff

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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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