
Transfer Pricing News in Luxembourg
Practical news and impacts in 2022 analysed for you
In the space of just a few years, Transfer Pricing policy has become an important issue, both in taxation and in the financial management of groups. Indeed, this is a field in constant evolution and affecting all aspects of taxation and current practice, resulting in case law, controversies, and litigations in Luxembourg and the European Union.
This situation is highlighted by a strong mobilization of the OECD and the European Union to limit the erosion of tax bases and the transfer of real or supposed benefits. As a result, international companies are all faced with the emergence of more demanding transfer pricing regulations.
To cope with this international complex environment, this fiscal event wishes to give an overview of the main events related to transfer pricing in 2022 and to explain the current and future expectation of authorities.
We are looking forward to meeting you at the conference.
- Overview on the principles and key events related to Transfer Pricinig
- Identify the current and future expectations of the authorities
- Tax managers
- Tax auditors
- International tax managers
- Accountant officers and managers
- Financial, tax and legal executives
- Tax lawyer
- Accountants
- Lawyers and consultants
- Administrators
- President and managing directors
- Chief financial officer
THURSDAY 6TH OCTOBER
Fiscal event animated by :
Benjamin TEMPELAERE
Transfer pricing Senior associate
ARENDT & MEDERNACH
&
Alexander GAWRONSKI
Manager Transfer Pricing
GRANT THORNTON LUXEMBOURG
&
Jean-Nicolas Bourtembourg
Head of International Tax / Transfer Pricing
GRANT THORNTON LUXEMBOURG
8.45 Welcome of participants
Opening of the session
Overview of principles and key events on Transfer Pricing in 2022 : LTA audits and OECD evaluations
- Reminder of Transfer Pricing’s principles and current regulations
- LTA audits of 2020-2021: practical lessons for taxpayers facing a tax audit in Luxembourg
- OECD 2022: Practical impacts and focal points of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and Transfer pricing profile of Luxembourg
Benjamin TEMPELAERE
Transfer pricing Senior associate
ARENDT & MEDERNACH
IBOR transition: main challenges and expectations in transfer pricing
- Structural differences between rates
- Re-examination of agreements / existing contracts and analysis of the fallback clauses
- Review of transfer pricing policies and methodologies: what additional documentation must be provided for Tax authorities?
Alexander GAWRONSKI
Manager Transfer Pricing
GRANT THORNTON LUXEMBOURG
&
Jean-Nicolas Bourtembourg
Head of International Tax / Transfer Pricing
GRANT THORNTON LUXEMBOURG
Coffee-networking
Overall approach of taxpayer and his activities : Interactions between VAT and Transfer pricing for intercompany transactions
- Principles of VAT and Transfer Pricing
- Article 80 VAT Directive / circular letter n°790 on 18/01/2019: anti-avoidance rule for EU Member States and Transfer Pricing adjustments
- Practical examples of VAT consequences after Transfer Pricing adjustments
- Tax and VAT authorities: trend of capturing big data to understand the overall activities of the taxpayer
Questions/answers
1.45 End of session