Transfer Pricing in Luxembourg

Inter-company training

Who is the training for?

Professionals of the financial sector aiming at acquiring a basic knowledge on transfer pricing principles and transfer pricing approaches accepted in Luxembourg.

Duration

8,00 hours(s)

Language(s) of service

EN

Goals

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

Contents

  • 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

Certificate, diploma

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

Additional information

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.

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