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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

In a judgment dated 3 March 2026 (No. 53701C ), the Higher Administrative Court ( Cour administrative, the “ Court”) dismissed an appeal brought by the Luxembourg State and confirmed that the Direct Tax Authority ( Administration des contributions directes , " DTA") had failed to establish the

On 19 December 2025, Luxembourg enacted the law amending (i) the law of 4 December 1967 concerning income tax (the “ LITL”) and (ii) the law of 23 December 2005 introducing a final withholding tax on certain interest income earned on savings (the “ Relibi Law”). The law was published in the Journal

On 2 October 2025, the Higher Administrative Court ( Cour administrative) issued a ruling in case n° 51646C (the “ Decision”), regarding the extent to which a former manager of a Luxembourg resident company called in guarantee may challenge the underlying tax assessments of that company. While the

On 6 June 2025, the Lower Administrative Court ( Tribunal administratif) issued two similar judgments in cases n° 49747 and 49749, rejecting the appeals lodged by a Luxembourg limited partnership ( société en commandite simple) against decisions of the director of the tax authorities and confirming

Pursuant to Article 137, paragraph 5a of the amended law of 4 December 1967 on income tax (the “ LITL”), and by way of derogation from the normal taxation system, remuneration paid by temporary employment contractors under an assignment contract to temporary employees whose agreed gross hourly wage