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DTSTART:20001029T030000
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UID:20260618T081908Z - 26880@eupv478
DTSTART;TZID=Europe/Luxembourg:20210520T140000
DTEND;TZID=Europe/Luxembourg:20210520T170000
CREATED:20260618T081908Z
DESCRIPTION:<a href="https://www.legitech.lu/event/transfer-pricing-and-rel
 ated-documentation-requirements-book-included-115/register">TRANSFER PRICI
 NG AND RELATED DOCUMENTATION REQUIREMENTS (BOOK INCLUDED)</a>\nPRESENTATIO
 N Luxembourg companies may enter into diverse commercial and financial tra
 nsactions with associated enterprises. The prices charged in regard to the
 se controlled transactions are called transfer prices. For Luxembourg tax 
 purposes\, these prices have to adhere to the “arm’s length principle
 ”. The arm’s length principle is the international transfer pricing st
 andard that OECD member countries have agreed should be used for tax purpo
 ses by MNE groups and tax administrations. The arm`s length principle requ
 ires that the remuneration for any transaction between related parties con
 form to that what would have been agreed if the transaction were to have t
 aken place between unrelated parties under comparable circumstances. The a
 rm’s length principle is firmly ingrained in Luxembourg tax law and has 
 been explicitly stated in article 56 of the Luxembourg Income Tax Law (LIT
 L). In addition\, several concepts and provisions under Luxembourg tax law
  require the arm’s length standard to be respected by Luxembourg compani
 es (the concepts of hidden dividend distributions and hidden capital contr
 ibution\, etc.). Over the last years\, transfer pricing has become the hot
  topic in Luxembourg taxation in an environment that relies increasingly l
 ess on tax rulings. In the past\, tax rulings were viewed as a way to prov
 ide certainty and to avoid risks when implementing investments or intra-gr
 oup transactions. However\, for a number of reasons this is no longer the 
 case and transfer pricing documentation is more and more filling the gap a
 s a tax risk management tool. As a member of the OECD\, Luxembourg adheres
  to the organization’s Transfer Pricing Guidelines which reflect the con
 sensus of OECD Member countries towards the application of the arm’s len
 gth principle as provided in article 9(1) of the OECD Model Tax Convention
 . In 2020\, a new chapter X has been added to the OECD [...]
DTSTAMP:20260618T081908Z
SUMMARY:TRANSFER PRICING AND RELATED DOCUMENTATION REQUIREMENTS (BOOK INCLU
 DED)
X-ALT-DESC;FMTTYPE=text/html:<a href="https://www.legitech.lu/event/transfe
 r-pricing-and-related-documentation-requirements-book-included-115/registe
 r">TRANSFER PRICING AND RELATED DOCUMENTATION REQUIREMENTS (BOOK INCLUDED)
 </a>\nPRESENTATION Luxembourg companies may enter into diverse commercial 
 and financial transactions with associated enterprises. The prices charged
  in regard to these controlled transactions are called transfer prices. Fo
 r Luxembourg tax purposes\, these prices have to adhere to the “arm’s 
 length principle”. The arm’s length principle is the international tra
 nsfer pricing standard that OECD member countries have agreed should be us
 ed for tax purposes by MNE groups and tax administrations. The arm`s lengt
 h principle requires that the remuneration for any transaction between rel
 ated parties conform to that what would have been agreed if the transactio
 n were to have taken place between unrelated parties under comparable circ
 umstances. The arm’s length principle is firmly ingrained in Luxembourg 
 tax law and has been explicitly stated in article 56 of the Luxembourg Inc
 ome Tax Law (LITL). In addition\, several concepts and provisions under Lu
 xembourg tax law require the arm’s length standard to be respected by Lu
 xembourg companies (the concepts of hidden dividend distributions and hidd
 en capital contribution\, etc.). Over the last years\, transfer pricing ha
 s become the hot topic in Luxembourg taxation in an environment that relie
 s increasingly less on tax rulings. In the past\, tax rulings were viewed 
 as a way to provide certainty and to avoid risks when implementing investm
 ents or intra-group transactions. However\, for a number of reasons this i
 s no longer the case and transfer pricing documentation is more and more f
 illing the gap as a tax risk management tool. As a member of the OECD\, Lu
 xembourg adheres to the organization’s Transfer Pricing Guidelines which
  reflect the consensus of OECD Member countries towards the application of
  the arm’s length principle as provided in article 9(1) of the OECD Mode
 l Tax Convention. In 2020\, a new chapter X has been added to the OECD [..
 .]
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