Transfer Pricing in Luxembourg

Upon successful completion of this course, the student will:

• have an overview of Luxembourg transfer pricing environment
• have an overview of the OECD Transfer Pricing Guidelines and the new guidance introduced as part of the OECD BEPS Project
• have a better understanding on Luxembourg transfer pricing rules and practices including the new Circular on the transfer pricing treatment of financing activities (Circular L.I.R. 56/1 and 56bis/1 released on December 27, 2016)
• have an overview of the functional and economic analysis in transfer pricing reports
• understand the impact of transfer pricing rules on the tax positions of Luxembourg companies
• understand the importance of transfer pricing documentation in a company’s risk management strategy

• Introduction to transfer pricing
  • The arm’s length principle
  • The OECD Transfer Pricing Guidelines
  • Luxembourg transfer pricing rules and practices
• Transfer pricing methodologies
• Comparability analysis and data base researches
• Common transfer pricing approaches applied in Luxembourg (financing activities, interest rates, intra-group services, fund management services, etc)
• Transfer pricing documentation and tax risk management
• Transfer pricing adjustments

At the end of the training, the participants will receive a certificate of participation delivered by the House of Training.

The lecturer is an International Tax Partner with a large tax advisory firm in Luxembourg where he is also heading the Transfer Pricing practice. A tax professional since 2003, he has experience in Luxembourg and international taxation with a focus on alternative Investments (private equity, real estate, sovereign wealth funds, hedge funds), mergers & acquisitions and multinational groups. He advises clients on all direct tax aspects regarding deal structuring, maintenance, reorganisations and exit planning.