Transfer pricing
Identifying the recent developments and opportunities.
Objectifs
Learning how to face the challenges related to transfer pricing, best practices and pragmatic approaches.
Pour qui ?
Prérequis
Compétences acquises:
Following the training, you will be able to analyse the main issues related to transfer pricing.
Programme
Transfer pricing
The international principles of transfer pricing
• The revelance of transfer pricing
• The arm's lenght principle
• Affiliation/related parties
• Identification and definition of intercompany transactions
• The core elements of a transfer pricing analysis
• Pricing models
• Documentation and reporting
Transfer pricing in Luxembourg
• Overview of the current Luxembourg laws and regulations
• Domestic transactions
• Fiscal unity
• Financial transactions (especially circular LITL no.56/1 - 56bis/1 of 27 December 2016)
• Transfer pricing for intangibles
• Penalty regime
A complete transfer pricing analysis
• Describing the circumstances under which intercompany transactions take place
• Analysis of functions and risks vs. value chain analysis
• The economic analysis and how it is used for determining transfer prices
Selected hot topics
• The asset management value chain and how to price it
• Considerations for developing and implementing transfer pricing policies
• Substance requirements
• Recent transfer pricing court cases
• Further developments on the horizon
