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By Oliver R. HOOR, Atoz*
On 3 July 2018, the OECD released the first public discussion draft on transfer pricing aspects of financial transactions (the “Discussion Draft”). The Discussion Draft, which has been published as a follow up work in relation to Actions 8 – 10 of the Base Erosion and Profit Shifting (“BEPS”) Project, aims to clarify the application of the principles included in the 2017 version of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (the “OECD TPG”). Since Luxembourg companies are frequently involved in financial transactions, the additional guidance provided in the Discussion Draft will be of utmost importance. This article provides a clear and concise overview of the content of the Discussion...
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