Our standard transfer pricing services include, in particular, the preparation of transfer pricing documentation and the determination of arm’s length prices & remunerations for:
- Financial intermediation activities (i.e. determination of ‘margin’ and equity at risk)
- Financing intermediaries (merely on-lending funds)
- A broad range of debt instruments, e.g. plain vanilla loans, convertible bonds, tracking debt
- Intra-group services (e.g. fund management, operational, administrative & support services)
In addition to the above, we offer assistance with:
- Master File, Local File & Country-by-Country Reporting (CbCR)
- Debt capacity analyses
- Design and implementation of transfer pricing policies
- Review and validation of transfer pricing positions (including alignment with legal documentation)
- Luxembourg tax authorities’ request of information & audit on transfer pricing matters
ATOZ Services
