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By Nicolas GILLET, Partner, Transfer Pricing Leader and Renaud LABYE, Tax Partner, EY Luxembourg
Under the current law, taxpayers must provide proof and relevant documentation when asked to verify the data on their tax return and ensure its accuracy. This general rule is also applicable to transfer pricing (TP) matters.
Following the recent submission of a draft law by the Luxembourg Minister of Finance to the Parliament(1), a draft Grand-Ducal Regulation (GDR)(2) was published in the first quarter of 2023 by the Luxembourg Government. This GDR details the obligation to be introduced for taxpayers with related enterprises to provide, upon request, specific documentation on their TP policy.
According to the GDR, Luxembourg...
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