Transfer pricing in the context of Alternative Investments


Proposed by

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

The new reporting obligations on intra group 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

Best practice recommendations

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Practical Info

24/11/2021 11:10 (Europe/Luxembourg)
1 hour 20 minutes