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By Danny BEETON, Arendt Medernach *
Multinational businesses face a new and challenging task of complying with the international community’s enhanced ‘transfer pricing’ rules of taxation. The response to the global recession of 2008 was politically-driven pressure on the OECD to tighten the international conventions on how the profits of multinational companies should be taxed. These new conventions have been converted into EU Directives and in changes to Luxembourg’s tax statute and its tax treaties with its trading partners.
The scope for international tax planning has been reduced and the burden of compliance with transfer pricing rules has increased significantly. Investment managers will certainly be affected by these changes, and...
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