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.
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VATCalc · about 3 hours ago
Continuous Transaction Controls (CTCs) are shifting VAT review from post‑return to real‑time monitoring, driven by e‑invoicing and e‑reporting mandates across the EU. The EU requires intra‑community transactions to be e‑reported within 10 days, while Spain and Poland have tighter deadlines of 4 days and live e‑invoicing to KSeF, respectively. VATCalc offers a single tax engine that integrates VAT determination, e‑invoicing, e‑reporting and return preparation for 30+ countries.
Deloitte Luxembourg · 11 days ago
On 13 May 2024, the CJEU ruled that contractual price adjustments in intragroup transactions are not considered a supply of services for VAT purposes, meaning such adjustments fall outside the scope of VAT. The decision applies across the EU, including Portugal and Luxembourg, and underscores the need for case‑by‑case assessment of transfer pricing adjustments. The ruling does not change VAT rates or thresholds but clarifies the treatment of these adjustments.
Law360 · 16 days ago
The EU's top court ruled that intercompany pricing adjustments between the former General Motors unit and Stellantis do not alter VAT liability, meaning the Portuguese government should not have increased the VAT bill for Stellantis. The decision clarifies that such pricing shifts are not subject to VAT adjustments.
VatCalc · 25 days ago
EU finance ministers endorsed an amendment to Regulation (EU) No 904/2010 that will allow OLAF and EPPO to query Member State VAT systems, but the amendment restricts access to read‑only, case‑by‑case searches and bans bulk extraction or AI analysis. The measure is pending Parliament approval, likely in July 2026, and will be routed through VIES, CESOP and Eurofisc channels.
Global VAT Compliance · 25 days ago
The European Commission’s proposed EU bill would require member states to share VAT data with anti‑fraud agencies, but Spain has raised objections over data access provisions and inconsistencies. The proposal, introduced in November, seeks to strengthen cooperation against VAT fraud, which the Commission estimates costs the EU €90 billion annually. Spain plans amendments ahead of the upcoming EU finance ministers meeting.
SAFT Validator · about 1 month ago
The article examines the ownership of the SAF‑T compliance process across European organisations, outlining the roles of tax, finance, IT, and external advisers. It highlights the challenges of multi‑country mandates and proposes a three‑layer model—accountability, operational ownership, and execution—to streamline responsibilities. The piece also notes the expanding SAF‑T requirements, such as Bulgaria’s 2026 launch, and stresses the importance of clear ownership for accurate, timely filings.
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Key Takeaways
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.
Primary source
Read the full article at Zanders GroupThis summary was published on VATfaqs.com on 27 January 2026. It relates to VAT developments in European Union. The original source is Zanders Group.
