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By Dinko DINEV, Partner and Tiziana CARLONE, Manager, Deloitte Tax Consulting
The pricing at market conditions of financial guarantees has attracted increased interest from the tax and treasury teams of many multinational enterprises (MNEs) across the world, following the OECD’s publishing of its Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10, which will become Chapter X of the OECD transfer pricing guidelines.
Luxembourg legislation does not explicitly address transfer pricing aspects of financial guarantee arrangements between related parties. However, article 56 bis of the Luxembourg Income Tax Law (LITL) emphasises the importance of the accurate delineation of the controlled...
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