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By Chiara PALMIERI, Nicolas GILLET, Vincent REMY, EY Luxembourg*
Securitization vehicles can be a powerful vehicle for carrying out third-party debt investment, but recent structuring options have introduced transfer pricing considerations that were previously overlooked. Market participants should be mindful of transfer pricing regulations while optimizing their strategies to leverage the flexibility of these vehicles. Adhering to the arm’s length principle can help manage associated risks. Proactive collaboration with tax and transfer pricing experts is crucial for ensuring compliance and achieving financial objectives.
Transfer pricing refers to the pricing of transactions, such as loans and goods, between related entities. It plays a...
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