Transfer pricing

For a company with cross-border intragroup transactions, TP policies create accounting, legal and operational challenges that are specific to their business. As businesses evolve, they face increasing demands from governments worldwide, and they require an operational transfer pricing (OTP) strategy that ensures data integrity, efficient integration with other key functional areas, and provides reporting transparency into the implementation of TP policy.

By analyzing specific group attributes and the broader industry landscape, our team selects the most appropriate solution from the range of approaches, tools and technologies available to design and solve specific TP policy implementation needs. Our transfer pricing professionals leverage advanced technology and automation to streamline compliance and boost productivity. Through strategic technology alliances, we can tailor technology solutions that integrate with existing ERP systems, establishing robust internal controls and transparent documentation. The results include stronger integrity across intragroup processes, greater operational efficiency, and reduced risk exposure, while also unlocking deeper insights and agility that help optimize strategies for future growth and regulatory adaptability.

Multinational companies operating in Luxembourg need to demonstrate that their intragroup transactions are compliant with the arm’s length principle.

Our team provides expertise across various stages of TP documentation preparation, including economic (benchmark) analyses to identify the arm’s length range of remuneration for specific inter-company transactions, assessments of cash and debt sustainability, drafting TP documentation for back-to-back financing structures in Luxembourg, and providing up-to-fully managed solutions such as outsourcing global TP documentation in line with OECD Guidelines and local requirements, including master files and local files for the entire Group.

Furthermore, we have dedicated solutions with respect to country-by-country reporting and related risk assessments, along with notification obligations.

In a world of uncertainty, advance pricing agreements with tax authorities provide a much-needed comfort and relief from expensive and time-consuming tax audits. We draw on our substantial experience assisting companies in obtaining Advance Pricing Agreements (APA) to support your business in developing bespoke strategies and processes for APA applications, including various interactions with tax authorities to facilitate a favorable outcome.

However, increased scrutiny towards TP globally and in Luxembourg leads to more challenges for transfer pricing policies applied by multinational groups.

Working together with our tax dispute resolution team, we provide a wide range of services, from stress-testing companies by conducting mock-TP audit procedures, to assisting in all stages of TP disputes, audits, court proceedings, mutual agreement procedures and exchanges of information.