Transfer Pricing in Luxembourg: How to manage tax risks in a world without rulings?
With the more recent introduction of reporting obligations on transactions with associated enterprises, the Luxembourg tax authorities made clear that they will increasingly focus on reviewing the arm's length nature of transfer prices. However, transfer pricing inevitably exerts pressure on taxpayers to find a balance between a comfortable level of security and the costs for the preparation of sound transfer pricing documentation. This briefing aims at providing participants with pragmatic and sustainable best practice recommendations.
Our agenda will include:
1. Overview
2. Snapshot of the Luxembourg transfer pricing landscape
3. Controlled transactions in Luxembourg
4. The new reporting obligations on intra-group transactions
5. The OECD Discussion Draft on TP aspects of financial transactions
6. Luxembourg finance companies: Approaches and recommendations
Determining an arm's length margin, active management of financing activities, risk management policy
7. TP documentation: Best practice recommendations
Requirements under Luxembourg tax law, how to manage tax risks in a world without rulings, striking a balance between costs and comfort
8. Conclusion