European Union: Transfer Pricing

The OECD's proposed revisions to Chapter VII of the Transfer Pricing Guidelines represent the most extensive rewrite of intra-group services guidance in years, introducing new requirements for accurate delineation, expanded benefit testing, and dedicated documentation standards. Loyens & Loeff's Transfer Pricing team has submitted detailed comments assessing whether these changes reduce compliance burdens or risk increasing double taxation for multinational enterprises.

Hungary’s proposed National Asset Recovery and Asset Protection Office may increase scrutiny of public funds, state aid, EU grants, transfer pricing and tax documentation. Learn what foreign-owned businesses should review now.

The OECD's Subject to Tax Rule (STTR) is being implemented through a Multilateral Convention, allowing source countries to impose additional taxation on cross-border payments between related parties when taxed below 9%. This treaty-based mechanism will reshape international financing, licensing, and service arrangements for multinational groups.

The Court of Justice of the European Union examines whether transfer pricing adjustments made within an intragroup agreement to guarantee a predetermined profit margin constitute taxable services under VAT law.

The principal provisions concern the transposition into Greek law of two EU Directives — 2023/2226 and 2025/872 (DAC8 and DAC9, respectively) — through amendments to Law 4170/2013 (the Law), the framework statute governing administrative cooperation in the field of taxation.

A statutory audit is a legal requirement for many Cyprus companies. But for companies with proper accounting departments, international groups with Cyprus subsidiaries, and management teams that rely on accurate...

The new edition of the EU Tax Alert is available. With this publication we would like to keep you informed about the latest developments on EU tax law. We have summarised the highlights of this edition below.

The recharacterisation of a share deal into an asset deal based on tax abuse is the Loch Ness monster of the Belgian real estate sector: everyone talks about it, but no one has ever actually seen it.

Pour justifier du taux de marché déductible appliqué à un prêt d'actionnaire, la CAA de Paris juge que des obligations émises en dollar ne constituent pas des comparables pertinents...