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.
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.
Portugal Introduces New Tax Incentive for Scientific Research and Innovation - IFICI
Portugal’s new R&D tax incentive (IFICI) allows companies to deduct 130% of qualifying expenses incurred through contracts with recognised research entities. Effective from FY2024, the measure targets projects driving scientific innovation and green or digital transitions.
The Hungarian Tax Authority’s 2025 Audit Plan: New Formats, Digital Tools, and Focus Areas
Hungary’s 2025 tax audit plan reveals an increasingly digital, data-driven approach. From AI-based risk analysis and a new data reconciliation procedure to enhanced enforcement and tighter scrutiny of trusts and e-commerce platforms — NAV is ramping up efforts to ensure compliance.
DAC6 Directive: Key Reporting Rules Across EU Countries
What makes a cross-border arrangement reportable under DAC6? Our guide breaks down how Luxembourg, Hungary, and Italy are applying the rules.