On 15 October 2026 the Court of Justice of the European Union (CJEU) delivered its judgment in Case C-203/25 “Neo Group”. The dispute concerns dividends that a Lithuanian company paid to its Cypriot parent under the exemption from withholding tax.
Companies that, in addition to their ordinary day-to-day transactions, transact with related parties - that is, carry out controlled transactions - have a number of obligations under the law.
The first part of this article set out the general principlesSee part 1 of this article (the general framework: types of PE, the 50% threshold and the commercial reason test, profit attribution and transfer pricing). 21); the OECD Council approved it on 18 November 2025.
On 9 July this year the Latvian Ministry of Finance opened the public consultation on draft law “Amendments to the Corporate Income Tax Law” (26-TA-85).
Imagine a situation: over several years, a company successfully develops its business. As a result, brand recognition is built, software and internal systems are developed, know-how is accumulated and a stable customer base is established.
Remote work has long outgrown its status as a temporary, pandemic-era fix and has settled in as a fully fledged model of work organisation. As a result, companies can bring in specialists regardless of where they are based, while employees can live and work where they choose.
A practical guide to setting up a group structure, separating risks and the related tax considerations. As a business grows, a single company often ends up holding several lines of business together with the related assets, functions and risks.