Documentation of how the Controlled Foreign Company (“CFC”) rules have been implemented.

TransFair Pricing Solutions - Scope


Prepare the Control test, associated enterprise test, Effective tax rate test, analyse and determine non-genuine arrangements, analysis of “significant people functions”, determine the relative contribution of the “significant people functions” carried out by the taxpayer and determine the amount to be included as CFC income in the commercial profit of the Luxembourg taxpayer.

TransFair Pricing Solutions - Purpose


  1. to comply with the tax authorities’ requirements in connection with CFC rules,
  2. to demonstrate the application of the CFC rules to the tax authorities and
  3. to avoid the risk associated with the taxation of the net income of the CFC.
TransFair Pricing Solutions - Deliverable


CFC documentation.

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