Transfer pricing is at the core of international trade and a vital issue for multinationals. Countries worldwide are today scrutinising inter-company pricing strategies and enacting rules to ensure appropriate allocation of income and assets among the various tax jurisdictions in which a multinational operates.
The transfer pricing environment in Luxembourg is evolving rapidly to embrace OECD standards and the latest developments in its Base Erosion and Profit Shifting initiative. On 27 December 2016, the Luxembourg tax authorities issued a circular regarding the tax treatment of Luxembourg companies engaged in intra-group financing activities, and they are increasingly focusing on the arm’s-length nature of other types of transaction.
Arendt has been active in tax advisory since the creation of the firm in 1988, and launched its transfer pricing practice in 2011. Initially focused on compliance with the requirements of the authorities' 2011 circulars establishing rules for inter-company financing, it has evolved to provide complete transfer pricing solutions to customers in sectors including investment funds, asset management, banking and insurance.
The transfer pricing team provides integrated services in close collaboration with lawyers from other practice areas to ensure the maximum quality of work for our clients.