The blog outlines emerging trends in intra‑group loan transfer pricing for 2026, highlighting recent court rulings in Luxembourg, Belgium, and the Netherlands that tighten documentation and credit‑rating requirements. It stresses the need for fact‑specific debt‑capacity analyses, robust credit‑rating methodologies, and clear contractual terms to mitigate audit risk. Multinationals should align loan terms with arm‑s‑length principles and document them comprehensively.
It rejected the automatic 85:15 debt‑to‑equity standard, stating that arm‑s‑length analyses must be fact‑specific and supported by data rather than mechanical ratios.
On 6 June 2025, it clarified that credit ratings must be substantiated and cannot be assumed based on group affiliation.
On 11 September 2025, it rejected the payment of guarantee fees, emphasizing the importance of factoring implicit support into the credit rating applied to the borrower.
They should prepare robust debt‑capacity analyses for each borrower entity, demonstrating that independent lenders would extend a similar amount of financing under comparable conditions.
Features such as subordination, maturity, interest structures, and repayment conditions must be clearly explained and aligned with the actual conduct of the parties.
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VatCalc · 2 days ago
The European Court of Justice issued three rulings on 12 March 2026 that clarified VAT deduction rights across the EU. The decisions confirmed that Spain can maintain its entertainment expense restrictions under Article 176, that late invoices do not preclude deductions if claimed within the limitation period, and that technical failures in electronic refund transmission cannot cancel refund claims. These rulings reinforce that VAT rights cannot be undermined by excessive formalism or administrative shortcomings.
The Invoicing Hub · 12 days ago
EN 16931‑1, the EU e‑invoicing standard, is being updated to a mid‑2026 release that expands B2B functionality and aligns with the ViDA initiative. The revision is not backward compatible, requiring migration for existing version 3 implementations, and will be formally approved in late January 2026 with publication concluding within six months. Key national roll‑outs include Germany’s XRechnung 4.0 and France’s CTC extensions.
Bloomberg Tax · 15 days ago
Bloomberg Tax’s commentary examines the European Commission’s proposal to grant EU anti‑fraud bodies access to national VAT data, a move aimed at closing the €128 billion annual VAT gap. The article highlights the debate over jurisdiction and the balance between cross‑border enforcement and national sovereignty.
LinkedIn Article by Raoul Ramautarsing · 18 days ago
The EU is set to overhaul its e‑commerce customs regime, abolishing the <EUR 150 exemption on July 1 2026 and replacing it with a flat EUR 3 fee per product. From November 1 2026 a EUR 2 handling fee will apply to all distance‑sale goods, while platforms will become deemed importers responsible for duties, VAT and compliance. A new customs data hub is slated for 2028 and dedicated e‑commerce warehouses are encouraged to mitigate the impact.
Baker McKenzie · 19 days ago
The CJEU reaffirmed that substantive VAT exemption conditions prevail over formalities, with three 2025 judgments clarifying that missing Article 45a documents, incomplete export paperwork, or absent customs steps do not automatically deny exemptions if fraud is absent. The rulings reinforce fiscal neutrality and outline narrow exceptions where formal non‑compliance can defeat an exemption.
Pagero · 22 days ago
The European Parliament’s Committee on Economic and Monetary Affairs released a draft report on 4 February 2026 urging the European Commission to overhaul the outdated 1977 VAT exemption for financial services. The report proposes taxing identifiable charges such as fees and commissions, introduces coordinated temporary windfall taxes on exceptional bank profits, and calls for an alternative to the withdrawn EU-wide Financial Transaction Tax.
