
We will provide the most recent updates and key elements to consider before closing the fiscal year 2021. In addition, we will provide an overview of the upcoming new reporting obligations.
Friday, 2 December 2022.
10:00 AM – 11:30 AM.
We will provide the most recent updates and key elements to consider before closing the fiscal year 2021. In addition, we will provide an overview of the upcoming new reporting obligations.
Friday, 2 December 2022.
10:00 AM – 11:30 AM.
The Leaders League awarded TransFair Pricing Solutions (“TFPS”) with the notation “Excellent” within the Best Transfer Pricing Agencies – ranking 2023 – Luxembourg.
This notation is thanks to the positive feedback of our clients and peers, and it recognizes TFPS’s high quality, expertise, commitment, independence, and fair solutions in the market.
Leaders League’s rankings comprise extensive research and interviews with company executives, in-house counsel, associations, institutions, and industry experts.
TFPS is an independent firm dedicated to providing tailor-made transfer pricing and valuation solutions to financial and corporate entities. TFPS team comprises transfer pricing and valuation experts who provide quality, expertise, commitment, independence, and fair solutions to its clients.
All details about the ranked companies are available at this link.
We will review the notion of substance for transfer pricing purposes and provide different perspectives considering recent new reporting obligations and court cases.
Friday, 25 November 2022.
From 10:00 AM to 11:30 AM
The International Tax Review (ITR) awarded TransFair Pricing Solutions (“TFPS”) with tier two ranking in the 2023 World Transfer Pricing guide. This tier rating is thanks to the positive feedback of our clients and peers, and it recognizes TFPS’s high quality, expertise, commitment, independence, and fair solutions in the market.
The World Transfer Pricing 2023 is a comprehensive guide to the world’s leading transfer pricing practitioners, which includes rankings and profiles of the most effective professionals in the world on this field, covering over 64 jurisdictions on every continent. ITR editorial team’s research produced this guide based on the feedback from the market and tax professionals around the world.
TFPS is an independent firm dedicated to providing tailor-made transfer pricing and valuation solutions to financial and corporate entities. TFPS team comprises transfer pricing and valuation experts who provide quality, expertise, commitment, independence, and fair solutions to its clients.
All details about the ranked companies are available at this link.
The Leaders League awarded TransFair Pricing Solutions (“TFPS”) with the notation “Excellent” within the Transfer pricing tax – ranking 2022 – Auditing and accounting firms – Luxembourg.
This notation is thanks to the positive feedback of our clients and peers, and it recognizes TFPS’s high quality, expertise, commitment, independence, and fair solutions in the market.
Leaders League’s rankings comprise extensive research and interviews with company executives, in-house counsel, associations, institutions, and industry experts.
TFPS is an independent firm dedicated to providing tailor-made transfer pricing and valuation solutions to financial and corporate entities. TFPS team comprises transfer pricing and valuation experts who provide quality, expertise, commitment, independence, and fair solutions to its clients.
All details about the ranked companies are available at this link.
The International Tax Review (ITR) awarded TransFair Pricing Solutions (“TFPS”) with tier three ranking in the 2022 World Transfer Pricing guide. This tier rating is thanks to the positive feedback of our clients and peers, and it recognizes TFPS’s high quality, expertise, commitment, independence, and fair solutions in the market.
The World Transfer Pricing 2022 is a comprehensive guide to the world’s leading transfer pricing practitioners, which includes rankings and profiles of the most effective professionals in the world on this field, covering over 64 jurisdictions on every continent. ITR editorial team’s research produced this guide based on the feedback from the market and tax professionals around the world.
TFPS is an independent firm dedicated to providing tailor-made transfer pricing and valuation solutions to financial and corporate entities. TFPS team comprises transfer pricing and valuation experts who provide quality, expertise, commitment, independence, and fair solutions to its clients.
All details about the ranked companies are available at this link.
The Global Advisory Experts (GAE) awarded TransFair Pricing Solutions (“TFPS”) as Transfer Pricing Advisory Firm of the Year in Luxembourg – 2021.
GAE has conducted its extensive nomination and research process for its 12th Annual GAE Awards. The shortlisted candidates were judged on client testimonials, key cases, rankings, overall reputation, publication contributions, speaking engagements and the performance and standing of teams and individual experts.
TFPS is an independent firm dedicated to providing tailor-made transfer pricing and valuation solutions to financial and corporate entities. TFPS team comprises transfer pricing and valuation experts who provide quality, expertise, commitment, independence, and fair solutions to its clients.
GAE is one of the world’s leading online resources for locating specialist advisers for the services required by businesses, investors and individuals around the world with over 40,000 users visiting our website each month. GAE is the premier guide to leading advisory experts throughout the world. It is the only organisation to recommend just one expert in each chosen specialism and country.
All details about the winner companies are available at this link.
The Leaders League awarded TransFair Pricing Solutions (“TFPS”) with the notation “Highly recommended” within the Transfer pricing – ranking 2021 – Law firm & Agencies – Luxembourg.
This notation is thanks to the positive feedback of our clients and peers, and it recognizes TFPS’s high quality, expertise, commitment, independence, and fair solutions in the market.
Leaders League’s rankings comprise extensive research and interviews with company executives, in-house counsel, associations, institutions, and industry experts.
TFPS is an independent firm dedicated to providing tailor-made transfer pricing and valuation solutions to financial and corporate entities. TFPS team comprises transfer pricing and valuation experts who provide quality, expertise, commitment, independence, and fair solutions to its clients.
All details about the ranked companies are available at this link.
A. Background & Scope
On 18 December 2020, the new Guidance on the transfer pricing implications of the COVID-19 pandemic was released by the OECD. This Guidance represents a consensus view of the 137 members of the Inclusive Framework on BEPS regarding the application of the arm’s length principle and the OECD Transfer Pricing Guidelines.
This guidance focuses on how the arm’s length principle and the OECD TPG 2017 apply to certain issues that may arise or be exacerbated in the context of the COVID-19 pandemic. In addition, this guidance is helpful both for taxpayers in reporting the financial periods affected by the pandemic and for tax administrations in evaluating the implementation of taxpayers’ transfer pricing policies.
B. Priority issues
This Guidance provides 31 pages with comments, illustrations, and the practical application of the arm’s length principle in four priority issues:
The following points highlight the scope and additional analyses necessary for managing each priority issue:
1. Comparability analysis
The pandemic may have a significant impact on the pricing of some transactions between independent enterprises and may reduce the reliance that can be placed on historical data. The impact may be a non-reliable comparability analysis.
This issue may require an analysis of the following aspects:
2. Losses and the allocation of COVID-19 specific costs
The allocation of losses between associated entities can give rise to disputes, and even more given the probable increase in the frequency and magnitude of losses in the current economic environment.
This issue may require an analysis of the following aspects:
3. Government assistance programmes
Grants, subsidies, forgivable loans, tax deductions, investment allowances, broader financial or liquidity supports together qualified as “government assistance programmes” could potentially have transfer pricing implications on the accurately delineated controlled transaction.
The impact may happen whether the government assistance is provided to a member of a multinational enterprise “MNE” group directly or made available to independent parties within the market where an MNE group operates.
This issue may require an analysis of the following aspects:
4. Advance pricing agreements (“APA”)
The existing unilateral, bilateral, and multilateral APAs might be not applied correctly because of disregard of the terms and breach of the critical assumptions as consequence of change in economic conditions driven by the pandemic.
This issue may require an analysis of the following aspects:
5. Takeaways
The application of the guidance for tackling the transfer pricing issues of the COVID-19 pandemic imply a cooperation between the tax administration and taxpayers in terms of flexibility and the exercise of good judgment.
In that regard, the next steps should be performed by taxpayers to ensure the application of this guidance on the existing and upcoming controlled transactions of the year 2020 and year 2021 (“intercompany transactions”), respectively:
Transfer Pricing Webinar
Register for our Webinar on 12th February at 10h00 AM to learn more about this new OECD Guidance.
On 16 December 2020, the Higher Administrative Court (“HAC”) ruled in favour of the Luxembourg Tax Authorities (“LTA”) in an appeal (N ° 45072) initiated by an Anonymous Company (“Luxembourg Company”), requesting an annulment of an information injunction arising from an exchange of information procedure between Luxembourg and Belgium.
The information injunction includes the request of information and documents of a related party in Belgium (“Belgium Company”) in connection with certain services received by the Luxembourg Company.
A. Background and facts
B. The Court’s decision
On 16 December 2020, the HAC concluded that the appeal is dismissed due to lack of foundation. Therefore, the HAC rejected it and ruled the following:
C. Takeaways
Transfer Pricing Webinar
Register for our Webinar on 29th January at 10h00 AM to learn more about this recent court case.