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Jul 07, 2026Transfer pricing | Proposed revision to Chapter VII of the OECD Guidelines on intra-group services
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
May 15, 2026Luxembourg Transfer Pricing Case Law | Undisclosed counter-guarantee subjected to TP adjustment
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
Mar 04, 2026Luxembourg case law | Qualification of a circular intra-group loss-generating structure as an abuse of law
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 ("
Jan 27, 2026Start-Up Investments | Tax credit for individuals: final law adopted
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
Sep 29, 2025ECJ Case law I VAT and Transfer pricing adjustment
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
Jul 09, 2025VEFA rental properties I Extension of the depreciation regime
On 30 June 2025, the government issued a Grand-Ducal Regulation aiming at amending the existing Grand-Ducal Regulation of 19 November 1999 implementing Article 106, paragraphs 3 and 4 of the Luxembourg income tax law (“ LITL”), which provides the depreciation regime and rates applicable to rental
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