Transfer pricing assistance | Deloitte solution
- New transfer pricing (“TP”) rules governing the acceptability of profits retained on intra-group debt financing structures established in Luxembourg need to be complied with as from 2012 to maintain or obtain a binding tax clearance on the financing margin in Luxembourg.
- It is important to be compliant to ensure that the structure’s cash repatriation mechanisms and ‘tax treaty access’ of relevant entities operate . Non-compliance may have adverse consequences on the issuance of certificates of residence and ultimately on beneficial ownership status.
- This involves reviewing the structure for compliance within the light of new rules and filing a TP analysis / advance pricing agreement with the Luxembourg tax authorities.
- We can provide all kind of assistance to make the structure TP compliant.
- Based on a technical TP analysis of your existing or future structure, our TP experts can assist you and provide you with practical advice around any changes needed to the structure to bring it to compliance.
- Advice is of course integrated with the relevant wider tax objectives of the structure to maintain its existing level of efficiency while ensuring the TP prerequisites are met at the same time.
- In the framework of the afore mentioned steps of analysis, our tax advisory assistance should ultimately be concluded through the submission of the advance pricing agreement to the Luxembourg tax authorities properly documented with the required TP analysis.
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