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, 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, Tax Litigation, International Compliance, Transfer Pricing, Digitalisation, White-Collar Crime, Transparency & Reporting Law & Numbers Network of Tax Lawyers Legal Updates, Tax Litigation, International Compliance, Transfer Pricing, Digitalisation, White-Collar Crime, Transparency & Reporting Law & Numbers Network of Tax Lawyers

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.

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