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By Dinko DINEV, Director – transfer pricing, Deloitte Luxembourg
Private credit markets have expanded significantly over the last decade,(1) with an increasing number of debt investment companies being set up in Luxembourg by private equity firms or hedge funds. The operating models adopted for these companies are evolving, driven by various economic, tax, and political developments internationally. Key players in the investment industry are stepping up their presence and functionality in the Grand Duchy. This article proposes a transfer pricing (TP) strategy that, in our opinion, aligns with these trends in the Luxembourg market.
Typical debt investment structures involve an investment fund (Fund) setting up a wholly owned Luxembourg company...
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