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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e-Invoice.app · 1 day ago
The European Commission will host a public workshop on 27 April 2026 to review the revision of Directive 2014/55/EU on e‑invoicing in public procurement. The event will outline potential policy measures, gather stakeholder feedback, and discuss the three policy options for the revision. The outcome will influence upcoming compliance requirements, including the ViDA reform that will mandate structured e‑invoicing for intra‑EU B2B transactions by July 2030.
Bloomberg Tax · 1 day ago
The article examines how fully automated, AI‑run companies—termed zero‑person companies—challenge existing VAT rules. It explains that while such entities can perform all operational tasks, they still require a human link for legal accountability, and their place of establishment for VAT purposes is determined by where central administration effectively occurs, often defaulting to the registered office. The piece also discusses the low likelihood of fixed establishments arising solely from cloud infrastructure and outlines compliance implications for tax authorities.
VATCalc · 4 days ago
The EU VAT reforms tracker outlines a comprehensive schedule of upcoming legislative and compliance changes across the EU, including new VAT registration thresholds, e-invoicing requirements, import VAT liabilities, and the Carbon Border Adjustment Mechanism. Key dates range from 2025 to 2035, covering digital services, e-commerce, and cross‑border trade. The tracker serves as a reference for businesses to anticipate and adapt to evolving EU VAT rules.
European Parliament · 8 days ago
The European Parliament and Council have agreed on a comprehensive reform of the EU Customs Code aimed at tackling the surge in e‑commerce parcels. Key measures include a new handling fee for individual parcels from non‑EU countries, treating e‑commerce platforms as importers, a new EU Customs Authority in Lille, and a customs data hub to be mandatory by 2034.
e-Invoice.app · 8 days ago
The article outlines a CFO-focused readiness scorecard for e-invoicing, highlighting gaps in regulatory awareness, technical infrastructure, process maturity, vendor coverage, and organisational alignment. It details key mandates in Belgium, France, and Germany, and stresses the importance of early assessment to avoid penalties and lengthy implementation cycles.
Bloomberg Tax · 8 days ago
Usage‑based billing for AI and SaaS services introduces VAT compliance challenges that stem from system design rather than legal ambiguity. Key issues include the timing of VAT on prepayments, the treatment of free usage, and the risk of late VAT declaration when true‑ups are billed at year‑end. The EU Court of Justice’s ruling on unused airline tickets illustrates how tax authorities view the right to service as a taxable supply.
