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 · 5 days ago
The article explains how the upcoming ViDA framework will eliminate tolerance for inconsistencies between VAT determination, invoicing and reporting, pushing control to the transaction level. It highlights that intra‑EU transactions will require near real‑time digital reporting, and notes key future dates for reverse‑charge harmonisation and the withdrawal of the European Sales Listing. The piece also discusses the implications for triangulation and supply‑chain transactions and promotes a single‑engine solution for compliance.
Bloomberg Tax · 6 days ago
The European General Court issued an order on 21 January 2026 in Case No. T-394/25, upholding the EU VAT deemed supplier model that requires online platforms to collect and remit VAT for short‑term accommodation rentals. The court found the taxpayer’s challenge inadmissible under the Treaty on the Functioning of the EU. This decision confirms the compliance obligations for platforms operating in the EU short‑term accommodation market.
Capto · 7 days ago
The article introduces a robot that automates the validation of EU VAT numbers via the VIES API, reducing manual effort and errors. It outlines a four‑step process that extracts VAT numbers from any file format, checks them against the VIES database, generates a PDF and Excel report, and emails the results. The service promises faster, 100% accurate validation and frees users to focus on higher‑value tasks.
Fincargo · 13 days ago
The ViDA directive amends Article 217 of the EU VAT Directive, requiring electronic invoices to be issued, transmitted, and received in structured formats such as XML, EDI, or Factur‑X. Effective 31 December 2030, the directive also removes the need for recipient acceptance and will trigger automatic pre‑filling of tax data, creating a velocity mismatch for businesses that still park invoices. Companies must transition to structured formats and reconcile pre‑filled data with their own books to avoid audit issues.
PwC Malta · 13 days ago
The European Commission’s ViDA strategy outlines a phased reform of VAT systems across the EU, introducing real‑time digital reporting, mandatory e‑invoicing, and platform‑economy rules. Key milestones include legislative clarifications (2025‑2027), platform rules for accommodation and transport (2028), mandatory e‑invoicing for intra‑EU B2B (2030), and full harmonisation of digital reporting (2035). The reforms aim to save businesses €51 billion and reduce fraud by up to €11 billion annually.
VatCalc · 14 days ago
The EU is proposing two new customs charges for small‑value imported parcels: a €2 handling fee effective November 2026 and a flat €3 duty on goods below €150 effective July 2026. These charges would be paid via the IOSS monthly return and could undermine the scheme by increasing costs and operational complexity. The measures are temporary, pending 2028 customs reforms, and will be reviewed every three months.
