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