Transfer Pricing Documentation

Scope

This solution provides an identification and summary of the main factors of comparability and economic results in line with the OECD Transfer Pricing Guidelines and local Transfer Pricing regulations. This includes the following:

1. A summary of comparability factors and economic results.
2. Details of company, intra-group transactions and arm’s length remuneration.
3. Financial statements of the parties.
4. Economic analysis.

Purpose

1. To demonstrate the application of the arm’s length remuneration in the: financial accounts, tax declaration, legal agreements and board minutes.
2. Reduce the tax risk associated with a possible tax or fiscal audit.

Deliverable

Excel converted into a pdf file (analysis + appendices).

Scope

This solution provides an identification and description of the main factors of comparability and economic results in line with the OECD Transfer Pricing Guidelines and local Transfer Pricing regulations. This solution includes the following chapters:

1. Background information,
2. Characteristics of the transaction,
3. Contractual arrangements,
4. Functional analysis,
5. Transfer pricing method,
6. Economic analysis,
7. Conclusions,
8. Recommendations ,
9. Appendices.

Purpose

1. To comply with the tax authorities’ requirements in connection with transfer pricing documentation.
2. Demonstrate the application of the arm’s length remuneration in the: financial accounts, tax declaration, legal agreements and board minutes.
3. Reduce the tax risk associated with a possible tax or fiscal audit.

Deliverable

Power point document converted into a pdf file (analysis + appendices).

Scope

This solution provides all the transfer pricing sections developed in an integral way to be compliant with the OECD Transfer Pricing Guidelines and local Transfer Pricing regulations. This solution includes the following chapters:

1. Background information,
2. Characteristics of the transaction,
3. Contractual arrangements,
4. Functional analysis,
5. Substance analysis,
6. Transfer pricing method,
7. Economic analysis,
8. Conclusions,
9. Recommendations,
10. Appendices.

Purpose

1. To comply with the tax authorities’ requirements in connection with transfer pricing documentation.
2. To demonstrate the application of the arm’s length remuneration in the: financial accounts, tax declaration, legal agreements and board minutes.
3. Fulfil requirements for Advance Pricing request to local tax authorities.

Deliverable

Word converted into a pdf file (analysis + appendices).

Scope

Preparation of a master transfer pricing documentation (“master file”) including the analysis of functions performed, risks assumed, and intangibles employed with respect to the main intercompany transactions within the Group. The master file is based on the arm’s length principle in accordance with the transfer pricing rules applicable in the specific jurisdiction and OECD Transfer Pricing Guidelines.

Purpose

1. To comply with the tax authorities’ requirements in connection with transfer pricing documentation.
2. Demonstrate that the Group clearly reflects the arm’s length remuneration attributable to intercompany transactions as they would with unrelated third parties.
3. Prevent commonly controlled entities from artificially shifting profit or loss between tax jurisdictions.
4. Reduce the tax risk associated with a possible tax or fiscal audit.

Deliverable

Master file documentation.

Scope

Preparation of the notification form which should be filed by any constituent entity of a Multinational Enterprise (MNE) group that is established in Luxembourg. This notification specifies whether the constituent entity is a reporting entity in Luxembourg and it should be prepared when the total consolidated turnover of the MNE group is equal or higher than EUR 750 million.

Purpose

To comply with the automatic exchange of information, legal requirement in connection with Country-by-Country Reporting.

Deliverable

Country by Country notification.