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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

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

On 11 February 2026, the Luxembourg Lower Administrative Tribunal ( " Tribunal ") (No. 47018) ruled on the existence of an abuse of law within the meaning of §6 of the Luxembourg tax adaptation law ( Steueranpassungsgesetz - " StAnpG "). Facts A Luxembourg private limited liability company ("

On 17 December 2025, the Luxembourg Parliament adopted the law introducing a tax credit for private individuals investing in innovative start-ups (the Law of 19 December 2025, the “ Law”). The Law applies as from tax year 2026. This Law follows Draft Law No. 8526 , submitted to the Luxembourg

On 4 September 2025, the ECJ delivered its decision in the Arcomet case ( C-726/23) following a request for preliminary ruling on whether intragroup remuneration adjustment for services, determined under the transfer pricing (“ TP”) Transactional Net Margin Method (“ TNMM”), is subject to VAT and