European Union: Transfer Pricing

The OECD's November 2025 updated Commentary on Article 5 of the Model Tax Convention introduces groundbreaking guidance on when cross-border remote working arrangements and home offices may create permanent...

Corporate groups commonly use intragroup guarantees to improve creditworthiness and secure favorable financing terms, but this practice carries significant tax implications under Polish transfer pricing regulations. When guarantees are provided free of charge or on non-equivalent terms between related parties, companies face risks including transfer pricing adjustments, additional tax liabilities of up to 20%, and taxation of gratuitous benefits. Understanding documentation thresholds, valuation methods, an

Belgium's tax administration has issued a crucial circular clarifying the application of the new capital gains tax on financial assets, addressing key uncertainties around realization timing, earn-out structures, partnership vehicles, and historical exemptions. The guidance provides essential insights for taxpayers navigating payment modalities, matrimonial property regimes, and the complex interaction between the tax and existing corporate structures.

Ireland's EU Presidency brings unique insights into European legislative processes, while recent tribunal decisions and regulatory changes reshape the landscape for tax enquiries, transfer pricing adjustments, and foreign investment screening. These developments signal important shifts in how tax authorities exercise their powers and how cross-border transactions are scrutinized across EU member states.

The European Commission's proposal to recast the Directive on Administrative Cooperation (DAC) represents a significant shift in tax transparency requirements, particularly targeting...

The Court of Justice of the European Union has ruled on whether intra-group transfer pricing adjustments constitute consideration for separate supplies of services subject to VAT. While the judgment provides clarity on routine profit margin adjustments, it raises questions about the broader treatment of year-end transfer pricing adjustments and their VAT implications for multinational enterprises.

Dutch tax law offers multiple facilities for tax-neutral corporate restructuring, both domestically and across borders. However, these opportunities require careful planning...

The European Commission is advancing a comprehensive simplification agenda for EU corporate taxation while simultaneously withdrawing proposals that lack political consensus. As negotiations on the next Multiannual Financial Framework intensify and digital taxation debates resurface, businesses face a recalibration of how tax policy supports EU objectives in practice.

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