Fast moving change and significant policy developments
Globalisation and the continued growth of international trade have made intercompany pricing a material and challenging issue for many businesses. The increasing complexity of businesses, the more aggressive tax authorities' audits and the harsher penalties regimes mean that making sure your transfer pricing strategy and execution are fit for purpose has become more important than ever before.
More and more countries are implementing new transfer pricing documentation requirements. At the same time, transfer pricing strategies are increasingly the subject of unwanted controversy. Also Luxembourg is following this general trend by increasing its focus on transfer pricing. The Luxembourg tax authorities issued two Circulars on the tax treatment of Luxembourg entities that are mainly engaged in intra-group lending activities. In addition, the Luxembourg Government announced that they envisage implementing general transfer pricing legislation in the course of 2014.
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