A new transfer pricing rules will take effect in Luxembourg from the year 2015 in line with international principles and OECD Tax Model convention providing adjustments of profit provisions if transfer pricing do not reflect the Arm’s Length principles.
The current legislation will also be amended to make clear that the disclosure and documentation requirement for taxpayers will also be applicable to support their tax return positions with respect to transactions between associated enterprises. This may result in a reversal of the burden of proof towards the taxpayer in the absence of proper transfer pricing documentation.
