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.
Belgium Introduces New Tax System for Carried Interest
Belgium’s new tax regime for carried interest introduces a 25% rate on the excess share of fund managers’ income above a normal investor’s return, with specific rules for capital gains on shares.
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.
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.
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.
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.
Comparative Tax Regimes for Holding Companies: Overview as of 2021
Explore how holding companies are taxed across key jurisdictions — from dividends to capital gains and beyond.