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 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.
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.
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.
The Key Features of the New Capital Gains Tax on financial assets in Belgium
A new capital gains tax regime will come into effect in Belgium on 1 January 2026. With a standard 10% tax rate, exemptions of up to €15,000, and special rules for significant shareholdings, this reform introduces notable changes for both private investors and entrepreneurs.
German “Immediate Investment Program 2025”: making targeted use of tax opportunities
Germany’s proposed “Immediate Investment Program 2025” introduces a suite of tax measures designed to boost corporate investment — from accelerated depreciation and electric vehicle incentives to long-term reductions in corporate tax rates. Businesses looking to invest in Germany should act strategically to seize these temporary but impactful opportunities.
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.
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.
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.
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.
Portugal to Close NHR Tax Regime to New Applicants in 2024
Portugal’s Non-Habitual Resident (NHR) tax regime is set to close to new applicants in 2024 — here’s what that means and what you should know before the end-of-year deadline.
Reverse Hybrid Entities: New Luxembourg Guidance on Taxable Income
New guidance from Luxembourg clarifies how Reverse Hybrid Entities should calculate taxable income — and includes a new reporting form.
Teleworking Abroad: When Does It Trigger a Permanent Establishment?
Remote work across borders can trigger unintended tax consequences. Here’s what companies need to know about permanent establishment risk.
Portugal: Tax Alert on Cryptocurrency Taxation
Portugal’s updated crypto tax rules bring exemptions for long-term holdings, new income definitions, and an “exit tax” for changing tax residence.
Taxation of a Secondary Residence in France Held by a Belgian Resident
Belgian residents with a second home in France: here’s what you need to know about taxation and cross-border rules, as explained by L&N experts.
Creating a Hungarian Subsidiary: Insights from German & Hungarian Lawyers
What should German investors know before opening a Hungarian subsidiary? In this video, two L&N members break it down — from legal steps to tax structuring.
Impatriate Tax Regimes in Luxembourg and Portugal: A Video Insight
Discover how Portugal’s NHR regime and Luxembourg’s expat incentives can benefit relocating professionals.
Luxembourg Tax Update – 2023 Budget Law
Luxembourg’s 2023 Budget Law introduces key updates to VAT, tax return deadlines, and incentives for impatriates and group employers.
New France–Belgium Tax Treaty (Part III): Wealth Tax (IFI) & Anti-Abuse Clauses
In this final part, we look at how France and Belgium will handle wealth tax and anti-abuse enforcement under their new treaty.
New France–Belgium Tax Treaty (Part II): Dividends, Interests & Capital Gains
The second part of our France–Belgium treaty alert explores cross-border treatment of dividends, interests, and capital gains.
New France–Belgium Tax Treaty (Part I): Real Estate & Treaty Overview
France and Belgium have signed a modernised tax treaty. Discover the first key updates around real estate and residency.