The importance of substance and transfer pricing in the post-BEPS era

1. Introduction
2. Agenda
3. Speakers

This training will be of significant importance for independent directors that need to have a clear understanding of substance requirements in international taxation, the new reporting obligations of tax intermediaries under DAC 6 (covering cross-border arrangements since June 2018) and the relevance of transfer pricing and related documentation when it comes to tax risk management.

While substance and transfer pricing have been important for Luxembourg companies since many years, the OECD Base Erosion and Profit Shifting (“BEPS”) Project only elevated their importance in an international tax environment that is characterized by total transparency and resulted in the adoption of a mandatory disclosure regime of potentially aggressive tax planning schemes in the EU (DAC 6).

The main features of the program are:

• Substance requirements: Analysing the reasons of substance requirements from a Luxembourg perspective, a foreign tax perspective, a tax treaty perspective and a transfer pricing perspective

• New reporting obligations of tax intermediaries (DAC 6): Analysing the scope of the new reporting obligations and the potential risks for taxpayers

• Transfer Pricing: Overview of the Luxembourg transfer pricing landscape, analysis of typical controlled transactions in an Luxembourg and best practice recommendations with regard to transfer pricing documentation

The training will be very practical with a view to provide participants with a clear guidance.

The training will be targeted to independent directors and people that would like to gain a clear understanding of the topics discussed.