ARTICLE · 10 OCTOBER 2017

Three Insights On Luxembourg's New Transfer Pricing Circular, Based On Our Client Experience

KPMG Luxembourg

Some time has now passed since the new transfer pricing circular for financing companies in Luxembourg ("Circular") was passed, and I would like to share with you three insights that I have gained...

LuxembourgTax

Philippe Neefs

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Some time has now passed since the new transfer pricing circular for financing companies in Luxembourg ("Circular") was passed, and I would like to share with you three insights that I have gained when helping clients to adapt to these new regulations. Since most intermediary intra-group financing companies ("Lux FinCos") need to be compliant before the end of 2017, now is the time to act if you have not yet adapted your structures.

1. What exactly does "qualified personnel" mean?

The Circular states that Lux FinCos should have "qualified personnel" capable of controlling the intermediary intra-group financing transactions. Clients often approach us to inquire what this term actually means in practice.

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Three Insights On Luxembourg's New Transfer Pricing Circular, Based On Our Client Experience

1. What exactly does "qualified personnel" mean?

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