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By Ralf HEUSSNER, Partner Tax | Transfer Pricing, Deloitte Luxembourg
It is time to revisit transfer pricing in the alternative asset management sector. New concepts introduced by the Organization for Economic Cooperation and Development (“OECD”) as part of the Base Erosion and Profit Shifting (“BEPS”) initiative in 2015 – aimed at aligning taxation with the economic activity that generates profits – are fundamentally reshaping the international tax landscape. This positions transfer pricing as one of the most contentious topics in today’s tax environment.
Additionally, the BEPS initiative has inspired many tax authorities around the world to follow their own interpretation of these new concepts. Scrutiny extends to formalistic aspects (i.e.,...
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