Luxembourg: recent developments in transfer pricing and tax ruling practice
By Denis-Emmanuel Philippe
The Luxembourg tax authorities are currently carrying out transfer pricing audits, particularly for financing companies. When the transfer prices are not substantiated through proper documentation, the Luxembourg tax authorities do not hesitate to reassess the tax bill, by adding an at-arm’s-length remuneration to the taxable basis. Recent decisions of the Luxembourg courts give further support to these attempts of the Luxembourg tax authorities. It is an understatement to say that transfer pricing is now becoming a serious concern for Luxembourg companies engaging in intra-group financing operations.
Apart from transfer pricing, there is another hot topic in Luxembourg: tax ruling practices. Two information injunctions were adopted by the European Commission on 24 March 2014, requesting Luxembourg to send information about its tax ruling practices and intellectual property tax regime before the end of this month. The aim of these information injunctions is to enable the commission to assess the compliance of Luxembourg’s tax ruling practice with EU state aid rules…
Click on the link below to read the rest of the DLA Piper briefing.
Sign in or Register to continue reading this article
It's quick, easy and free!
It takes just 5 minutes to register. Answer a few simple questions and once completed you’ll have instant access.Register now
Why register to The Lawyer
In-depth, expert analysis into the stories behind the headlines from our leading team of journalists.
Identify the major players and business opportunities within a particular region through our series of free, special reports.
Receive your pick of The Lawyer's daily and weekly email newsletters, tailored by practice area, region and job function.
More relevant to you
To continue providing the best analysis, insight and news across the legal market we are collecting some information about who you are, what you do and where you work to improve The Lawyer and make it more relevant to you.
News from DLA Piper
News from The Lawyer
Briefings from DLA Piper
A well-known British performing artist was granted permission to take his case to the Supreme Court, where he will appeal the Court of Appeal’s decision in OPO v MLA & STL.
The increased focus of national data protection authorities on the processing of personal data through mobile apps was again confirmed in an open letter from a group of data protection authorities.
Analysis from The Lawyer
Regulators are ramping up the pressure in the aftermath of recession, leaving firms to compete for compliance and restructuring work
Shearman & Sterling is making its presence felt in the City, squaring up to magic circle firms and looking to muscle in on key relationships. Private equity house Bridgepoint is one outfit that has had its head turned by the US firm.