Transfer pricing in motion — navigating global complexity
Transfer Pricing
Cross-border intercompany transactions present significant challenges and opportunities for businesses. Increasing complexity, stricter documentation requirements, and growing demands for tax transparency underscore the need for a robust transfer pricing strategy. Ongoing changes introduced by the OECD, the EU, and national governments require continuous monitoring and, where necessary, timely adjustments to your transfer pricing policies to ensure compliance.
Our diverse team of transfer pricing specialists can help you manage risks, identify opportunities, enhance efficiency, and develop compliant structures aligned with your business objectives.
Your opportunities
Companies are navigating a complex landscape of evolving international tax regulations and stringent documentation requirements. Key challenges include ensuring compliance with diverse local and global rules, stricter deadlines and managing the risk of double taxation. At the same time, tax authorities are rapidly adopting AI, big data, and real-time digital reporting tools to detect inconsistencies and enforce compliance.
At PwC Luxembourg, we help you turn these challenges into opportunities. By combining deep technical expertise with cutting-edge technology such as AI and automation, we support you in building resilient, future-ready transfer pricing strategies. Developing robust transfer pricing strategies and engaging in proactive reviews are now essential to withstand audits and algin with global standards, while ensuring sustainable positions.
Our multidisciplinary team works alongside you to co-create tailored solutions that align with your business strategy, enhance compliance, and unlock long-term value. Together, we help you move forward with precision, agility, and confidence.
How we can help
Services
We provide comprehensive services to ensure that your transfer pricing arrangements for financing transactions comply with stringent regulatory, documentation, and audit requirements. Our expertise includes adherence to the 2017 Luxembourg Transfer Pricing Circular, as well as Articles 56 and 56bis of the Luxembourg Income Tax Law. These provisions emphasise the importance of maintaining adequate economic substance and applying the arm’s length principle in intra-group financing transactions.
Our support includes:
- Interest rate benchmarking studies
- Yield reasonability analyses
- Debt capacity analyses
- Credit rating estimations
- Cash pooling arrangements
- Review and preparation of intercompany agreements
- Valuation services
Adapting your business model or entering new markets can significantly affect your transfer pricing strategy. At the same time, the growing emphasis on sustainability, transparency, and evolving internal priorities makes it essential to reassess your current approach. We work closely together with our Business Model Reinvention team and guide you in designing and implementing robust, future-ready transfer pricing models tailored to your company’s unique needs.
Our services include:
- Functional analysis
- Transfer pricing model strategy
- Value chain analysis and/or transformation
- Peer group analysis and identification of key industry value drivers
- Restructuring and OECD Chapter IX analysis
- Transfer pricing model implementation and monitoring
- Defence documentation
As global tax regulations tighten, especially under the OECD’s Base Erosion and Profit Shifting (BEPS) framework, multinational companies face increasing pressure to maintain consistent and transparent transfer pricing documentation. We help businesses align their transfer pricing policies with both local and OECD standards, offering strategic risk reviews and documentation support. Our support includes a three-tiered approach to transfer pricing documentation: Master File, Local File, and Country-by-Country Report ("CbCR"). Transfer pricing advice and subsequent documentation will often involve more than one country. In such cases, we apply PwC’s TP Reports™ system, which offers a streamlined alternative to help multinationals meet the requirements of multiple jurisdictions in an efficient and coordinated manner. We can help you reinvent your end-to-end (E2E) strategy and processes, leading to a more streamlined approach, reduced workload, increased accuracy of charges, significantly enhanced transparency, and — not least — well-positioned documentation to support future reviews, including local statutory audits.
We work closely with our Tax Controversy and Dispute Resolution team in cases of disputes, tax audits, or information requests relating to transfer pricing. We can assist in managing transfer pricing disputes involving two or more jurisdictions through various dispute resolution procedures. To reduce uncertainty regarding a prospective tax position, we can support you in obtaining Advance Pricing Agreements (APAs) from the tax authorities in Luxembourg. Additionally, where a multi-country approach is more appropriate, we can assist in securing multilateral APAs.
Industries
- Alternative Investments (ALTS)
- Asset and Wealth Management (AWM)
- Industry & Services (I&S)
- Insurance
- Banking
Our added value
- Strong local footprint with global reach
- Innovation powered by AI
- Human-led, tech-enabled
- Strategic support from end to end
- Smart documentation at scale
Strong local footprint with global reach
Our Luxembourg-based team combines deep local expertise with diverse international backgrounds, seamlessly connected to PwC global Network. We help you navigate complexity with confidence, wherever you operate.
Innovation powered by AI
We use advanced AI and automation to reimagine your transfer pricing function - enhancing accuracy, streamlining compliance, and unlocking insights that drive smarter decisions and sustainable value.
Human-led, tech-enabled
Our approach blends trusted human expertise with powerful digital tools. By working across Tax, Advisory, and Assurance, we deliver integrated, forward-looking solutions tailored to your business.
Strategic support from end to end
From value chain transformation and bespoke transfer pricing models, to proactive risk monitoring and dispute resolution, we go beyond compliance to help you build long-term resilience and value.
Smart documentation at scale
With PwC's proprietary TP Reports™ technology, we deliver consistent, efficient, and scalable documentation across jurisdictions - reducing administrative burden and audit risk.
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