Transfer Pricing in Luxembourg

Formation inter-entreprise

À qui s'adresse la formation?

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

Durée

4,00 heure(s)

Langues(s) de prestation

EN

Prochaine session

Objectifs

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

Contenu

  • 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

Certificat, diplôme

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

Informations supplémentaires

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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