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On 5 January 2026, the OECD Inclusive Framework issued additional guidance on the application of the Global Anti-Base Erosion Model Rules (“ Pillar Two” or the “ GloBE Rules”). This guidance covers several topics, most notably the “Side-by-Side Safe Harbour”, which is currently applicable to US

On 31 July 2025, the Belgian Constitutional Court referred a request for a preliminary ruling to the European Court of Justice (the “ ECJ”) on the compatibility of Council Directive 2022/2553 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and

On 8 May 2025, Advocate General Kokott (AG Kokott) handed down her Opinion in the case C-744/23, Т.P.T. v Financial Bulgaria’ EOOD on the Value-Added Tax (VAT) treatment of a contingency fee, paid in the event of a successful legal case. In the case at hand, a one-person law firm provided legal

On 27 February 2025, the Court of Justice of the European Union (CJEU) handed down a decision on the procedural rights of administrators which may be held jointly and severally liable for the VAT debts of the companies they administer. As a reminder, many Member States including Luxembourg provide

On 11 December 2024, the Luxembourg Indirect Tax Authorities ( Administration de l’enregistrement, des domaines et de la TVA) issued a new circular No. 781-2 on the VAT treatment of director’s fees following the decision of the European Court of Justice (the “ ECJ”) in case C-288/22, TP v

On 25 th April 2024, the Luxembourg Higher Administrative Court handed down a judgment (48917c) regarding the right to carry-forward tax losses for Luxembourg companies. In the case at hand, a company which had previously engaged in a holding activity and generated tax losses, acquired and sold a