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
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
Professionals of the financial sector aiming at acquiring a basic knowledge on transfer pricing principles and transfer pricing approaches accepted in Luxembourg
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.
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.
At the end of the training, the participants will receive a certificate of participation delivered by the House of Training.