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By Marc Rasch, Transfer Pricing partner, Lise Lozano-Moury, Transfer Pricing manager, Rémy Boulanger, Transfer Pricing senior advisor, PwC Luxembourg
Since the Luxembourg tax authorities (LTAs) issued guidelines on transfer pricing regarding the intercompany financing transactions in 2011, transfer pricing in Luxembourg has emerged a new era. Indicators include a recent court case that scrutinised the interest rates applied by a Luxembourg tax payer, and the coalition programme of the Luxembourg government announcing the introduction of new transfer pricing regulations. What’s more, on a global level, the OECD is paying increasing attention to Based Erosion and Profit Shifting (BEPS).
A transfer price designates the price at which goods, services,...
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