Insights Across Borders

Our members share updates, reflections, and guidance on the evolving tax landscape — from legislative developments and case law to international structuring and cross-border insights.

Each article is contributed by a member of the L&N network and reflects both technical excellence and practical experience in jurisdictions around the world.

Legal Updates, Incentives, Investment Income, Corporate Structuring, Cross-Border Advisory Law & Numbers Network of Tax Lawyers Legal Updates, Incentives, Investment Income, Corporate Structuring, Cross-Border Advisory Law & Numbers Network of Tax Lawyers

Luxembourg Carried Interest Reform: Key Changes from 2026

Luxembourg plans to overhaul its carried interest regime from 2026, introducing two distinct categories with reduced rates or potential exemptions, expanding eligibility, and allowing deal-by-deal models. Fund managers should prepare for significant changes.

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Legal Updates, Transfer Pricing, Cross-Border Advisory, Corporate Structuring, Tax Litigation, International Compliance Law & Numbers Network of Tax Lawyers Legal Updates, Transfer Pricing, Cross-Border Advisory, Corporate Structuring, Tax Litigation, International Compliance Law & Numbers Network of Tax Lawyers

Luxembourg Court Rejects 85:15 Debt-to-Equity Rule in Intra-Group Financing

In a landmark ruling (Case No. 50.602C), the Luxembourg Higher Administrative Court rejected the use of the 85:15 debt-to-equity ratio as a binding safe harbour for intra-group financing. Instead, companies must apply a tailored transfer pricing analysis to determine debt capacity, based on what third parties would have agreed under arm’s length conditions.

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