Transfer pricing has become more and more important in recent years with the implementation of specific regulations and, consequently, of ever heavier documentation and compliance requirements but also with the development of new business practices with regard to either transfer of goods and services or intangible property and financial transactions – one of the principle Luxembourg industries.
This Review provides a wealth of local country transfer pricing information
Sean Foley, KPMG's Head of Global Transfer Pricing Services shares his view on the BEPS Action Plan.
The tax authorities are watching out to increase their tax revenue and scrutinize accordingly the respect of the arm's length principle in all intra-group operations. It is therefore of utmost importance that multinational enterprises manage their transfer pricing risks in light of the growing local and global pressure from tax authorities worldwide.
Transfer pricing is however not only a question of audits, adjustments and penalties. It is above all a precious instrument for international tax planning which can be used for cash management purposes and for business models' restructuring to improve the efficiency and profitability of groups worldwide.
KPMG Luxembourg transfer pricing department can offer you a wide range of services such as:
- Global restructuring of activities and management of international projects (e.g. high-level analysis of a transfer pricing restructuring)
- Tax efficient supply chain management
- Advanced tax negotiations with the Luxembourg tax authorities
- Intellectual property planning
- Pricing of financial instruments
- Functional and risk analysis
- Benchmarking analysis
- Luxembourg and global documentation in coordination with foreign KPMG offices