Transfer Pricing

The importance of substance and transfer pricing in the post-BEPS era

Transfer Pricing

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The importance of Transfer Pricing in the post-BEPS era

  • Snapshot of the Luxembourg transfer pricing landscape

  • The arm's length principle

  • Tax risks in relation to transfer pricing

  • Typical controlled transactions in Luxembourg

    • Intra-group loans and other debt instruments

    • Financing activities

    • Intra-group services

    • Fund management services

  • The new reporting obligations on intra-group transactions

  • The OECD Discussion Draft on transfer pricing aspects of financial transactions

  • The transfer pricing regime applicable to Luxembourg finance companies

  • Transfer pricing documentation

    • Documentation requirements under Luxembourg tax law

    • Management of tax risks in the absence of tax rulings

    • Guidance provided under the OECD Transfer Pricing Guidelines

    • Best practice recommendations

About The Author

Practical Info

26/02/2019 16:30 (Europe/Luxembourg)
1 hour 30 minutes