Corporate Tax News

Issue 80 - November 2026

Multinational groups with related-party transactions in Japan may need to strengthen their intercompany agreements, invoices and cost-allocation support under new supplementary recordkeeping requirements. This issue of Corporate Tax News leads with an examination of how those requirements apply alongside existing transfer pricing documentation rules.

Proposed legislative changes include Luxembourg’s 2027 Budget Bill, which would lower the corporate income tax rate, while Denmark’s government is advancing a broad package of proposed business tax reforms. 

Recent court decisions are also reshaping the landscape. In the EU, the CJEU has further clarified the Parent-Subsidiary Directive’s anti-abuse rule and Denmark’s Supreme Court has extended the limitation period for certain withholding tax reclaims.

Businesses should prioritise immediate reviews of related-party documentation, dividend and supply-chain structures, and potentially recoverable Danish withholding tax. They should separately model the Luxembourg and Danish proposals, which remain subject to legislative approval. Across these developments, authorities and courts are placing increasing emphasis on substance, economic purpose and contemporaneous documentation. The Japanese, EU and German developments show that legal form alone may not determine the tax outcome: decision-makers are examining how transactions operate in practice, who benefits economically and whether the supporting records explain the commercial rationale.

With this final issue, BDO’s Corporate Tax News comes to a close. We thank our readers for their support and engagement over the years. Please stay tuned for a new approach to tax content—one designed to deliver timely analysis, practical insights and a clearer view of what developments mean for businesses.