The application of the arm's length principle (ALP) is not always easy or free from conflict between taxpayers and tax authorities and this is especially true for countries with low resources and limited reliable sources of...more
The TP Directive’s stated goal is to increase tax certainty, reduce compliance costs, and mitigate the risk of double-taxation and litigation for cross-border intra-group transactions within the EU. The TP Directive would...more
More than four yeas after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail.
...more
More than four years after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail. As expected, the new...more