VAT and intragroup transactions
VAT risks and opportunities arising from intra-group transactions should not be underestimated. Operations such as mergers, recharge of costs or transfer pricing adjustments can quickly become particularly complex from a VAT standpoint. Additionally, the implementation of a VAT group should not be taken lightly as it can be complex to handle in practice.
In this course, we will guide participants through common issues and pitfalls that arise from transactions occurring within related entities.
Duration: 4h
Language: Available in English and French. The supporting material is only available in English.
Number of participants: up to 15
Available as intra-company course (i.e. dedicated session on demand)
Course content can be customised on demand under specific conditions.
Objectives
By the end of this training, participants will be able to:
- name the VAT opportunities and risks associated with the implementation of a VAT group;
- determine the relation between VAT and transfer pricing adjustments;
- draw up a list of concrete VAT implications of intra-group transactions, in particular recharge of costs, mergers and transfer of seats;
- identify pros and cons of VAT grouping for their organisation.
Content
The course will focus on specific VAT topics and issues arising between related parties to enable learners to identify the associated risks, opportunities and best practices. This course is not industry-specific. The experts will use practical examples from different industries according to the audience.
- VAT implications of cross-border transactions between a head-office and a branch
- VAT treatment applicable
- VAT recovery right implications
- Relevant case law
- VAT grouping regime: main principles and key points to consider for implementation
- What is a VAT group?
- What are the conditions to apply for it?
- How to apply?
- Pros and cons
- Transfer pricing adjustments and open market value
- Transposition of the article 80 of the European VAT Directive into the Luxembourg VAT Law
- VAT treatment of transfer pricing adjustments: taxable or out of the scope?
- What are the VAT practical consequences of transfer pricing adjustments?
- Intra-group restructuring
- Transfer of an ongoing concern
- Transfer of seat
- Merger and de-merger
- Understand the key concepts of undisclosed agent and disclosed agent and their practical implications
- What are the differences between an undisclosed agent and a disclosed agent?
- What are the VAT implications surrounding these two concepts?
- Recharge of costs: pitfalls and best practices
- Practical implications
- Best practices and guidelines
Target audience
- Managers and financial or fiscal directors in charge of VAT management for Luxembourg
- Accountants in charge of the preparation and filing of Luxembourg VAT returns
We recommend having a basic VAT knowledge prior to attending this course.
Our lead experts
This training is coordinated by Marie-Isabelle Richardin, Tax Partner in the PwC VAT department.
This training will be delivered by our field expert trainers, as identified by Marie-Isabelle.
Marie-Isabelle Richardin is a partner at PwC with over two decades of experience in VAT practice, specialising in assisting financial services operators with indirect-taxation strategies to ensure compliance and reduce tax burdens at both Luxembourg and international levels. She has held leadership roles within PwC’s VAT practice and gained international experience through assignments in New York and London. Marie-Isabelle is a frequent speaker and trainer on VAT for financial services, a guest lecturer at the University of Luxembourg, and has chaired the VAT working group of the Luxembourg Private Equity Association. She also represents PwC Luxembourg in VAT groups of key industry associations including ALFI and EFAMA. Her expertise covers financial transactions, investment funds, asset management, and VAT compliance, with notable client projects involving private equity, real estate, hedge funds, management companies, and banks.
