Loans and guarantee fees - Regfollower

Luxembourg: Administrative Court rules on transfer pricing treatment of debt restructuring

11 August, 2026

The Luxembourg Administrative Court (Cour administrative) issued its decision in case 53194C on 22 July 2026, concerning the application of the arm’s length principle to an intra-group debt restructuring and the deductibility of interest

Russia: MOF publish clarification guidance for TP purposes

29 November, 2021

On 18 November 2021, the Russian Ministry of Finance (MoF) published a Guidance Letter No. 03-03-07/85525 clarifying that a loan is considered a controlled debt for Transfer Pricing (TP) purposes if it is granted to a Russian company by a third