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, Tax Compliance, Incentives, Corporate Tax, Reporting Obligations, Cross-Border Advisory, Personal Income Law & Numbers Network of Tax Lawyers Legal Updates, Tax Compliance, Incentives, Corporate Tax, Reporting Obligations, Cross-Border Advisory, Personal Income Law & Numbers Network of Tax Lawyers

Biennial Preventive Agreement (CPB): What You Need to Know in 2025

Italy’s new CPB regime allows eligible taxpayers to agree on their income in advance for two years, reducing audit risks. Available from 2025, it offers predictability and tax simplification — but requires full compliance and careful evaluation before opting in.

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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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Legal Updates, International Tax, Trade & Customs, Cross-Border Advisory, Transparency & Reporting Law & Numbers Network of Tax Lawyers Legal Updates, International Tax, Trade & Customs, Cross-Border Advisory, Transparency & Reporting Law & Numbers Network of Tax Lawyers

Trade War of Tariffs: What It Means for EU and Hungarian Businesses

New U.S. import tariffs introduced by the Trump administration are reshaping global trade dynamics. Hungarian businesses exporting to the U.S. should prepare for increased rates, shifting exemptions, and complex origin rules — while keeping a close eye on the EU’s evolving countermeasures.

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Legal Updates, International Mobility, International Employment, Social Security, Double Taxation, Cross-Border Advisory, Permanent Establishment, Personal Income Law & Numbers Network of Tax Lawyers Legal Updates, International Mobility, International Employment, Social Security, Double Taxation, Cross-Border Advisory, Permanent Establishment, Personal Income Law & Numbers Network of Tax Lawyers

Foreign Employment: Navigating Tax and Social Security Across Borders

Sending employees abroad brings more than logistical challenges — it introduces a web of tax and social security rules that vary by country, duration, and employment structure. This article unpacks Hungary’s approach to postings and what businesses must consider when operating across borders.

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