Transfer Pricing - Advanced

Globalisation and the ongoing growth of international trade have rendered intercompany pricing a material and challenging issue for many businesses. One of the main difficulties lies in identifying the transfer pricing exposures and transactions, ensuring compliance with the arm's length principle.

This advanced module led by PwC's experts will address questions on how to manage transfer pricing within participants' companies, considering different stages of the business. It will explore how to assess and monitor potential transfer pricing exposures, identify the parties interested in transfer pricing, and examine how various reporting mechanisms can impact transfer pricing.

By the end of this training, participants will be able to:

• understand how to identify the transfer pricing exposures
• apply the identification of the transfer pricing exposures to their business
• be aware of the different reporting requirements and how that could impact their transfer pricing policy
• understand the interested parties in transfer pricing

Main topics to be covered during the session (amongst others):

• Transfer pricing lifecycle
• Substance and governance
• Chapter X - Financial transactions
• Chapter IX - Restructuring
• Transfer pricing audit
• Latest transfer pricing developments in Luxembourg and abroad

This training is coordinated by Marc Rasch, Partner in charge of transfer pricing.

This training will be delivered by our field expert trainers, as identified by Marc Rasch.

• Marc Rasch is a partner in the Transfer Pricing team in Luxembourg, specialising in transfer pricing with a focus on financial transactions, banking, operational industry, country-by-country reporting, and dispute resolution. With over 20 years of experience in transfer pricing and international taxation, he advises multinational companies and banks. Prior to joining PwC Luxembourg, he worked in Paris and the Netherlands. Marc has extensive sector experience including financial services, consumer goods, pharmaceuticals, chemicals, entertainment, apparel, automotive, and food and beverages. He regularly publishes articles, speaks at seminars, and has been recognised as a leading transfer pricing specialist in Luxembourg by Euromoney/International Tax Review.