Transfer Pricing analysis and documentation

Mitigate the tax risks of your financial investment is our priority

Are you facing one of the following business challenges?

« How to determine the tax rate to apply to our financings? »

« What is the margin on the intra-group services used by our entities? »

« How to split the margin between our Luxembourg head office and our foreign branches? »

« What are the transfer pricing consequences of our proposed restructuring? »

« Should we apply for a bilateral or unilateral APA? »

« Can our TP policy have an impact on other tax than corporate tax? »

We would be pleased to help you with answering these operational questions.

We delineate your financial transactions and understand your business goals before defining your own TP policy according to the arm length principle.

Then, we advise your group to modify your financing structure, if any, and draft the cost-effective documentation to mitigate the tax risks related to your financial investment.

We assist you with the drafting of the corporate documents, and support tax audits or advance Pricing agreement request.

Transfer Pricing
analysis

  • Determination of interest rates on debt instruments
  • Analysis of the debt-equity capacity of the borrower
  • Attribution of profits between the branch and the head office

Transfer Pricing
documentation

  • Drafting of TP reports
  • CBCR
  • Assistance for foreign local and master files

Discussions with
tax authorities

  • Unilateral Advanced Pricing Agreement
  • Bilateral Advanced Pricing Agreement
  • Luxembourg tax audits
  • Management of foreign tax audits with local advisors

Our practical views

Does the tax audit of a Luxembourgish financing structure only focus on the interest rate of the loans ?

Should my Luxembourgish company order a Transfer Pricing report for its current loans or receivables?