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This article analyses recent Luxembourg guidance on the tax treatment of companies carrying out intragroup financing activities.
Over the last decades, Luxembourg has developed and cemented its position as a prime holding location and a major financial centre within Europe. Multinational enterprises and international investors alike use Luxembourg as a platform to manage their business activities and investments. 0Luxembourg companies may enter into diverse commercial and financial transactions with associated enterprises. The prices charged in regard to these controlled transactions are called transfer prices. For Luxembourg tax purposes, these prices have to adhere to the "arm?s length principle".0The arm?s length principle is the international transfer pricing standard that OECD member countries have agreed should be used for tax purposes by MNE groups and tax administrations. 0The arm?s length principle is firmly ingrained in Luxembourg tax law and has been explicitly stated in article 56 of the Luxembourg Income Tax Law (LITL). In addition, several concepts and provisions under Luxembourg tax law require the arm?s length standard to be respected by Luxembourg companies. 0In 2020, a new chapter X has been added to the OECD Transfer Pricing Guidelines that provides guidance on transfer pricing aspects of financial transactions which are a common phenomenon in Luxembourg. 0On 18 December 2020, the OECD further provided guidance on the application of the arm?s length principle and the OECD Transfer Pricing Guidelines to issues that may arise or be exacerbated in the context of the so-called COVID-19 pandemic and the financial turmoil resulting from government responses thereto.0This book analyses all facets of Luxembourg transfer pricing rules and relevant guidance in the 2020 version of the OECD Guidelines.
Luxembourg finance companies must now comply with the requirements of a new transfer pricing circular: the risk management function is of crucial importance for such companies.
Luxembourg finance companies must now comply with the requirements of a new transfer pricing circular: the risk management function is of crucial importance for such companies.
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The authors, in this note, describe the new circular on the tax treatment of companies carrying out intra-group financing activities, which was released by the Luxembourg tax authorities on 27 December 2016 and is effective 1 January 2017.
This book explores transfer pricing issues related to intra-group financing transactions. It is an invaluable resource for tax practitioners, tax lawyers, tax managers, tax directors of corporations, treasurers and tax authorities, in all facets of transfer pricing and intra-group financing.
Luxembourg is a preferred location for the structuring of intra-group financing activities. Finance companies need to report an arm's length remuneration on their financing activities in conformity with the OECD Transfer Pricing Guidelines. This article depicts a remuneration model for finance companies.
In this article, the author analyses the scope and mechanics of Luxembourg's new controlled foreign company (CFC) rules and considers problems such as overlap with transfer pricing rules and the risk of double taxation.
Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing Developments in the European Union; Transfer Pricing Developments in the United States; Transfer Pricing Developments in Developing Countries and Emerging Economies; Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Nexus Rules); Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Profit Allocation Rules); Recent Developments on Transfer Pricing and Intra-Group Financing; and Recent Developments on the Use of New Technologies for Transfer Pricing Analyses. The intense work of international organizations, such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations, as well as the intense work of the European Union is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel and academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.