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Jul 09, 2026Luxembourg embraces amount B I Accepting OECD transfer pricing outcomes for in-scope distribution activities
Background On 13 April 2026, the Direct Tax Administration ( Administration des contributions directes ) (the " DTA") published Circular L.I.R. No. 56/2 - 56bis/2 (the " Circular"), confirming Luxembourg’s adoption of the OECD’s simplified and streamlined approach to the arm’s length principle for
Jul 09, 2026Cross-Border Fund Marketing | What fund managers need to know about ESMA's latest review?
ESMA flags persistent gaps in cross-border fund marketing compliance ESMA's cross-border fund marketing review confirms that, almost four years after the cross-border distribution of funds regime entered into force, many managers still fall short of regulatory expectations. ESMA has published its
Jul 09, 2026LuxSE Rules & Regulations and Trading Manual | June 2026 Updates
The Luxembourg Stock Exchange (the " LuxSE") has published updated versions of its Rules & Regulations (“ R&R") and Trading Manual (“ TM"), both effective June 2026. The updates touch three distinct areas: alignment with the EU Listing Act package, preparation for the shift to T+1 settlement, and a
Jul 07, 2026MAR | STOR audits, public disclosure and insider list
Three recent developments under the Market Abuse Regulation (Regulation (EU) No 596/2014) (" MAR") warrant attention. On 8 May 2026, the ESMA published an update to its Questions and Answers on MAR (the " Q&A") clarifying the annual audit obligation under Commission Delegated Regulation (EU) 2016
Jul 07, 2026CJEU case I VAT treatment of loan servicing
On 17 June 2026, the General Court of the European Union handed down a judgment in case T-184/25 – Veronsaajien oikeudenvalvontayksikkö v A Oy on the VAT treatment of loan servicing. The judgment has significant implications for Luxembourg securitisation transactions. Facts of the case A Oy is the
Jul 07, 2026Transfer pricing and VAT | No taxable service without a direct legal nexus
In its judgment of 13 May 2026 in Case C-603/24 , Stellantis Portugal, S.A. (successor to General Motors Portugal (" GMP")) v Autoridade Tributária e Aduaneira , the Court of Justice of the European Union (" CJEU") confirmed that transfer pricing adjustments implemented to achieve a predetermined
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