Loyens & Loeff
Bloomberg Tax BNA

Bloomberg Tax Transfer Pricing Forum - Luxembourg - Fall 2018

The Arm’s Length Nature of Intercompany Financing Transactions The OECD’s recent publication Discussion Draft on Financial Transactions addresses the Report on Actions 8-10 of the BEPS Action Plan, which includes transfer pricing guidance for related party financial transactions.
The goal of this forum is to identify the current status of the country’s specific rules, best practices, and court cases applicable to determining and supporting the arm’s length nature of intercompany financing transactions (including the terms of the instrument and the pricing of the transaction) and the potential impact of the discussion draft.

Peter Moons, Gaspar Lopes Dias and Fernanda Rubim give their insights as regards to the Luxembourg jurisdiction. 

Discover their full analysis here.

Transfer Pricing Forum, volume 9, Issue 3, October 2018, p.50, ed. Bloomberg Tax BNA