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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Pagero · 1 day 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Economic and Monetary Affairs released a draft report on 4 February 2026 urging the European Commission to overhaul the outdated 1977 VAT exemption for financial services.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introduces coordinated temporary windfall taxes on exceptional bank profits, and calls for an alternative to the withdrawn EU-wide Financial Transaction Tax.
The Invoicing Hub · 2 days ago
The Peppol network will enforce a mandatory switch from G2 to G3 digital certificates on 1 April 2026. Failure to migrate will revoke the G2 trust chain and disconnect Access Points from the network. OpenPeppol has issued detailed guidelines to help providers become dual‑capable during the transition.
Fonoa · 3 days ago
The blog explains how embedding tax automation into marketplace platforms can unlock revenue, reduce risk, and support compliance across multiple jurisdictions. It outlines platform reporting obligations in the EU (DAC7), UK, Mexico, Canada, Australia, and other countries, and highlights the benefits of integrated tax services for sellers and platform operators.
VatCalc · 3 days ago
The EU will eliminate the €150 customs and VAT threshold for low‑value consignments from March 2028, making e‑commerce platforms the de‑emed importers responsible for all duties and VAT. A single EU Customs Authority and a Customs Data Hub will be established to centralise and simplify customs procedures, with the new regime expected to raise €1 billion in revenue annually.
Zampa Partners · 4 days ago
The article examines the Tour Operators’ Margin Scheme (TOMS), highlighting its intended simplification for travel agents and the significant challenges it poses, such as blocked input VAT and inconsistent application across EU Member States. It discusses the scheme’s impact on profitability, competitive distortions, and the European Commission’s public consultation on reforms launched in 2025.
RTC Suite · 4 days ago
On 13 February 2026 CEN approved updates to EN 16931‑1, modernising the standard for B2B e‑invoicing and ViDA‑driven reporting across the EU. The revision adds mandatory fields such as IBAN details, early‑payment discount and late‑payment charge indicators, and clarifies syntax bindings to UBL and UN/CEFACT CII, requiring businesses to adapt validation and mapping processes for automated compliance.
