Luxembourg:
Transfer Pricing Guidelines
25 January 2022
Loyens & Loeff
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With this alert we would like to update you on the latest
Transfer Pricing developments. As of today, the new 2022 edition of
the OECD Transfer Pricing Guidelines for Multinational Enterprises
and Tax Administrations is available.
The OECD Transfer Pricing Guidelines
for Multinational Enterprise and Tax
Administrations provide guidance on the application of the
"arm's length principle". In a global economy where
multinational enterprises play a prominent role, Transfer Pricing
continues to be high on the agenda of tax administrations and
taxpayers alike.
The new 2022 edition incorporates:
- revised guidance on the application of the transactional profit
method adopted in 2018,
- guidance for tax administration on the application of the
approach to hard-to-value intangibles agreed in 2018,
- guidance on financial transactions approved in 2020, and
- consistency changes have been made to the rest of the OECD
Transfer Pricing Guidelines.
Curious about the updates? Our Transfer Pricing experts Natalie
Reypens, Harmen
van Dam, Peter
Moons and Fabian
Sutter are available for queries.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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