Cette formation est proposée sous forme de formation présentielle.

Description

Objectives

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, including the OECD 2020 guidance on financial transactions

  • 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

Programme
  • 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  

Target Audience

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

Lecturer

The lecturer is a Principal in the International and Corporate Tax department with a large tax advisory firm in Luxembourg.

A tax professional since 2011, the lecturer worked in the accounting sector for 2 years in France before focusing on international tax in Luxembourg. The lecturer has experience in relation to the structuring of Alternative Investments via Luxembourg (private equity, real estate, hedge funds, debt funds, etc.) as well as mergers & acquisitions (multinational groups). The lecturer advises clients on all direct tax aspects regarding deal structuring, maintenance, reorganisations and exit planning. The lecturer is a member of the Core Transfer Pricing Team of an independent advisory firm.


Conditions

Course Material

Please note that for environmental reasons no paper version of the training material will be provided for your training. The course material can be downloaded free of charge via your portal before the start of the course (download the Client Portal User’s Guide here). You will be able to view it on the screen of your mobile device or print it if necessary. If your registration has been made by a training manager of your company please contact him/her so that he/she can give you access to it or send it to you.

Certificate

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

Location
Chambre de Commerce Luxembourg
7, rue Alcide de Gasperi
L-1615 Luxembourg
Luxembourg
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