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By Dinko DINEV, Director, Transfer Pricing Mariana COHEN MARGIOTTA, Manager, Transfer Pricing, Deloitte
On 11 February 2020, the OECD released the report Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10 (the Report). The Report will be included as Chapter X of the internationally regarded OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD Transfer Pricing Guidelines). The Report is the first dedicated guidance issued by the OECD in the area of intra-group financial transactions. This article discusses three key transfer pricing (TP) implications for Luxembourg.
As a financial center of global significance,...
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