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Loyens & Loeff
The EUGC appears to accept this would be the case even if there is no arm's length principle clearly laid down in domestic law.
Luxembourg
Arendt & Medernach
On 30 March 2020, the Luxembourg government filed Bill of law No 7547 implementing certain guidelines approved by the Council of the EU on 5 December 2019 related...
NautaDutilh Avocats Luxembourg
On 30 March 2020, the Luxembourg finance minister introduced a bill ("the bill") aimed at implementing European Union (EU) recommended preventive measures.
Arendt & Medernach
On Saturday 21 March 2020, the Luxembourg Parliament passed a law implementing Council Directive (EU) 2018/822 of 25 May 2018 amending Directive 2011/16/EU as regards mandatory...
ATOZ Tax Advisers
On Saturday 21 March 2020, the Luxembourg parliament passed the law implementing the Council Directive (EU) 2018/822 of 25 May 2018 ("DAC6") regarding the mandatory exchange of ...
ELVINGER HOSS PRUSSEN, société anonyme
On 11 February 2020, the OECD released the final version of the transfer pricing guidance on financial transactions – a long-awaited report after the draft published on 3 July 2018 ("Report").
Arendt & Medernach
On 3 July 2018, the OECD launched a consultation on the transfer pricing of financial transactions by publishing the first draft of a new chapter…
Loyens & Loeff
In the course of 2019 there were several developments in EU tax law. This annual edition of EU Tax Alert provides an overview of those developments.
ATOZ Tax Advisers
After many years of reforms encouraged by the OECD's BEPS Action plan, it seems as if Luxembourg is now on the home stretch of the BEPS reform marathon
KPMG Luxembourg
A debt-to-equity (D/E) analysis determines if the forecasted debt level and capital structure of a company meet the arm's length standard.
ELVINGER HOSS PRUSSEN, société anonyme
In a judgment of 24 September 2019, the General Court of the European Union ("Court") dismissed actions brought by Luxembourg and Fiat Finance and Trade
ATOZ Tax Advisers
The idea to tax the digital economy shifts slowly towards new taxation rights and new profit allocation rules that may affect more than just tech companies.
KPMG Luxembourg
The last few years have seen some big changes in the corporate tax world – from ATAD1 & 2 and the EU Commission's anti-tax avoidance package to the recent US tax reform.
KPMG Luxembourg
Luxembourg has recently enacted a new intellectual property (IP) regime in line with the OECD recommendations for more tax transparency, and in June an administrative circular was issued to help clarify this regime.
ATOZ Tax Advisers
On 8 August 2019, a draft law implementing the Council Directive (EU) 2018/822 of 25 May 2018 as regards mandatory automatic exchange of information in the field of taxation in relation to reportable
ATOZ Tax Advisers
On 8 August, the draft law (the "draft law") implementing the EU Directive 2017/952 of 29 May 2017 ("ATAD 2") amending Directive (EU) 2016/1164
KPMG Luxembourg
Business restructurings are normally associated with a transfer of functions, risks, or assets between the entities of a group—and that means transfer pricing consequences.
KPMG Luxembourg
The EU Joint Transfer Pricing Forum (JTPF) assists and advises the European Commission on transfer pricing tax matters. Recently, it issued a report on the application of the profit-split method
ATOZ Tax Advisers
Over the last few years, transfer pricing and related documentation has become the hot topic in Luxembourg taxation in an evolving environment that is relying increasingly less on tax rulings
KPMG Luxembourg
The asset management industry in the United Kingdom is the one of the biggest in the world, while Luxembourg is often cited as a key jurisdiction ...
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