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  

Duration : Two half day session

Schedule : 2:00pm to 6:00pm

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 tax partner (Head of Transfer Pricing) with a large tax advisory firm in Luxembourg who has 15 years of experience in Luxembourg and international taxation. He published more than 170 articles and books on Luxembourg and international taxation including Transfer Pricing and the OECD Base Erosion and Profit Shifting (“BEPS”) Project, EU Law and EU State Aid investigations. He is also member of the Taxand transfer pricing service line.

The course material will be delivered at the end of the course.