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, including the OECD 2020 guidance on financial transactions

• 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  

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

The lecturer is a Principal in the International and Corporate Tax department with a large tax advisory firm in Luxembourg.

A tax professional since 2011, the lecturer worked in the accounting sector for 2 years in France before focusing on international tax in Luxembourg. The lecturer has experience in relation to the structuring of Alternative Investments via Luxembourg (private equity, real estate, hedge funds, debt funds, etc.) as well as mergers & acquisitions (multinational groups). The lecturer advises clients on all direct tax aspects regarding deal structuring, maintenance, reorganisations and exit planning. The lecturer is a member of the Core Transfer Pricing Team of an independent advisory firm.