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On 22 July 2026, the Luxembourg Higher Administrative Court ( Cour administrative ) (the “ Court”) (No. 53194C ) clarified the framework to assess the arm’s length character of a debt restructuring as well as the rules applicable to the accounting of debt and related interest for tax purposes. Facts

On 18 June 2026, the OECD released a Public Consultation Document proposing a revision of Chapter VII of the OECD Transfer Pricing Guidelines (“T P Guidelines”) on intra-group services, which seeks to align the existing guidance with the foundational principles set out in Chapters I-III. The

In a judgment of 20 May 2026 (No. 48972 ), the Lower Administrative Court ( Tribunal administratif , the “ Tribunal”), Fifth Chamber, overturned a decision of the Direct Tax Administration (the “ DTA”) and ruled that debts recorded by a Luxembourg subsidiary under a private-law tax-sharing agreement

Key takeaways On 9 June 2026, the Luxembourg Government submitted eleven amendments to draft law No. 8676 introducing the Single Tax Class and individual taxation as the default personal income tax regime from 2028 onwards. The amendments follow the Council of State’s opinion of 5 May 2026 and

The Luxembourg Government filed Draft Law No 8782 (the " Draft Law") with the Luxembourg Parliament ( Chambre des Députés ) on 1 July 2026, proposing a comprehensive reform of the tax regime applicable to employee stock option plans under the Luxembourg Income Tax Law of 4 December 1967, as amended

On 18 March 2026, the Luxembourg Administrative Tribunal ( Tribunal administratif, No. 48905) ruled on the TP implications of an intra-group financing operated through a Luxembourg PE involving guarantees. Following a Belgian tax adjustment and a spontaneous exchange of information, the Luxembourg