Transfer pricing in Luxembourg: What Directors have to know

Introduction

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

Coffee break

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

Conclusion