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> > > MODULE 3: TRANSFER PRICING AND RELATED DOCUMENTATION REQUIREMENTS

MODULE 3: TRANSFER PRICING AND RELATED DOCUMENTATION REQUIREMENTS

Droit fiscal

Date : 03/03/2020 Horaires : 14h00 - 17h00 (accueil à partir de 13h30) Lieu : Novotel Kirchberg

Thématique : Legitech en collaboration avec ATOZ Tax Advisers

Workshop: Structuring Alternative Investments (Private Equity, Real estate, etc.) in the post-beps era

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. 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 standard that OECD member countries have agreed should be used for tax purposes by MNE groups and tax administrations. The arm`s length principle requires that the remuneration for any transaction between related parties conform to that what would have been agreed if the transaction were to have taken place between unrelated parties under comparable circumstances.

The arm’s length principle is firmly ingrained in Luxembourg tax law and has been explicitly stated in article 56 of the Luxembourg Income Tax Law (LITL). In addition, several concepts and provisions under Luxembourg tax law require the arm’s length standard to be respected by Luxembourg companies (the concepts of hidden dividend distributions and hidden capital contribution, etc.).

Over the last years, transfer pricing has become the hot topic in Luxembourg taxation in an environment that relies increasingly less on tax rulings. In the past, tax rulings were viewed as a way to provide certainty and to avoid risks when implementing investments or intra-group transactions. However, for a number of reasons this is no longer the case and transfer pricing documentation is more and more filling the gap as a tax risk management tool.

As a member of the OECD, Luxembourg 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 Model Tax Convention.

Transfer pricing and the OECD Transfer Pricing Guidelines received a lot of attention during the OECD/G20 in their Base Erosion and Profit Shifting (BEPS) initiative. 4 of the 15 BEPS Actions aimed at providing new or changing existing transfer pricing guidance and related documentation requirements. As a result thereof, several chapters of the OECD Guidelines have been significantly amended or replaced in the 2017 Revision thereof.

 

Objectives of the workshop

Upon successful completion of this workshop, the participants will:

  • have an overview of the Luxembourg transfer pricing environment
  • have an overview of the OECD Transfer Pricing Guidelines and the new guidance introduced as part of the OECD BEPS Project
  • have a better understanding on Luxembourg transfer pricing rules and practices including the new Circular on the transfer pricing treatment of financing activities (Circular L.I.R. 56/1 and 56bis/1 released on December 27, 2016)
  • understand the impact of transfer pricing rules on the tax positions of Luxembourg companies
  • understand the importance of transfer pricing documentation in a company’s risk management strategy

*     *     *

INTERVENANTS

Oliver R. Hoor, Tax Partner, ATOZ Tax Advisers

Oliver is a Partner in the International and Corporate Tax department of ATOZ.

A tax professional since 2003, Oliver has experience in Luxembourg and international taxation with a focus on alternative Investments (private equity, real estate, sovereign wealth funds, hedge funds), mergers & acquisitions and multinational groups. Oliver advises clients on all direct tax aspects regarding deal structuring, maintenance, reorganisations and exit planning.

He is Head of Transfer Pricing and the German Desk. Oliver is further a member of the tax working groups of the Association of the Luxembourg Fund Industry (ALFI) and the Luxembourg Private Equity Association (LPEA).

Oliver is the author of more than 250 articles and books on Luxembourg and international taxation including Transfer Pricing and related documentation requirements, the OECD Base Erosion and Profit Shifting (“BEPS”) Project and the EU Anti-Tax Avoidance Directives
(ATAD 1 & 2), reporting obligations of tax intermediaries (DAC 6), the OECD Model Tax Convention and Tax Treaties, EU Law and the State Aid investigations of the EU Commission. He is also a regular speaker at conferences as well as a lecturer with House of Training, Legitech and ILA.

Oliver is qualified as a Chartered Accountant in Luxembourg (“Expert-Comptable”) as well as a certified German tax adviser (“Steuerberater”). He holds a post-graduate degree in Luxembourg Tax and a degree in Business Administration with a major in Tax from the University of Applied Sciences of Trier (Germany).

 

Fanny Bueb, Tax Director, ATOZ Tax Advisers

Fanny is a Director in the International and Corporate Tax department at ATOZ.

A tax professional since 2011, Fanny worked in the accounting sector for 2 years with a Big4 in France before focusing on international tax in Luxembourg. Fanny has experience in relation to the structuring of Alternative Investments via Luxembourg (private equity, real estate, infrastructure, etc.) as well as mergers & acquisitions (multinational groups). She also provides tax advisory services to clients in the Luxembourg banking area with a particular focus on the treatment of transactions under Luxembourg GAAP and IFRS.

Fanny is a member of the Core Transfer Pricing Team of ATOZ that develops new transfer pricing services and deals with complex, non-standard transfer pricing engagements. She further advises on the new reporting obligations of tax intermediaries under the mandatory disclosure regime (DAC 6).

Fanny holds a post-graduate degree in Luxembourg Tax. She holds a Master’s degree in Accounting (French GAAP, IFRS), Finance and Management as well as a Master’s degree in Business and Tax Law from the University of Strasbourg (France).

 

Cette formation d’une demi-journée est agréée par le Barreau de Luxembourg dans le cadre de la formation continue. ?

Prix : 345€ HTVA

Tarif étudiant : 48,55€ HTVA, soit 50€ TTC (à condition d’envoyer une copie de sa carte étudiant)

 

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