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.
When Transfer Pricing Meets VAT: The CJEU’s Arcomet Ruling Explained
The CJEU’s Arcomet ruling clarifies that transfer pricing adjustments may, under certain conditions, constitute VATable services — urging companies to review intra-group settlements with both tax and VAT implications in mind.
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 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.
COVID-19 & Transfer Pricing: Adapting Benchmarks and Documentation in France
COVID-19 forced French businesses to rethink their transfer pricing benchmarks — and strengthen both documentation and contractual safeguards.
French and Belgian Members Co-Author Article on Transfer Pricing Between Jurisdictions
A recent publication on France–Belgium transfer pricing reflects the close collaboration between L&N members across jurisdictions.