Arendt & Medernach views transfer pricing as one of its core practice areas. The firm offers a full suite of transfer pricing services to its clients, including advisory, benchmarking, economic analysis, design, implementation and defence of transfer pricing policy. The department includes notable professionals, including partner Alain Goebel and of counsel Danny Beeton.
The practice was involved in the establishment of Asset Management One Alternative Investments' first Luxembourg global infrastructure debt fund. The reserved alternative investment fund, operating with the master-feeder model, allows Japanese investors to invest into the global infrastructure market through a Luxembourg RAIF. It has also advised the client on the regulatory and transfer pricing provisions related to fund formation, as well assisting with all necessary documentation and policy implementation.
Of counsel Danny Beeton joined the firm in May 2018. He holds a PhD in Economics and was formerly the head of transfer pricing economics at Freshfields Bruckhaus Deringer and managing director at Duff & Phelps.
Deloitte Luxembourg offers one of the largest tax departments in the country, and holds a team of 30 transfer pricing specialists, including four partners in a team of lawyers, economists and industry specialists. Stephan Tilquin jointly acts as the talent leader and the transfer pricing leader for the firm. Xavier Sotillos Jaime and Ralf Heussner are notable partners, with both specialising in value chain analysis. It acts on all transfer pricing matters, with a key position within the financial services industry.
The department has been involved in a number of Brexit contingency plans and restructurings, with analysis of the effects of each project on the transfer pricing model and offering necessary changes to the current policy. It is also currently advising on what will be the first bilateral APA signed between Luxembourg and another EU jurisdiction. It has been involved in the design and economic analysis of this APA as well as the its filing management and negotiation.
Partner Xavier Sotillos Jaime joined the team in September 2018, following a four-year tenure as partner with PwC in Paris. He has also held senior transfer pricing positions in both Germany and Spain.
The EMEIA Tax Center at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness Platform, Solutions & Intelligence and operational transfer pricing practice serving clients’ needs across all jurisdictions.
Led by well-recognised, Oslo-based partner Sveinung Baumann-Larsen, the operational transfer pricing team brings together multi-disciplinary experience and resources focusing on IT, accounting, and tax from the entire region to bring to bear in its work. This work covers some of the leading global companies in their respective fields and includes those involved in retail and consumer products, energy and pharmaceuticals.
KPMG holds a leading presence within the Luxembourg transfer pricing market, with a particular strength in advising asset management clients as well as broader financial services clients. The team is led by Philippe Neefs, with support from partners Sophie Boulanger and Pawel Wroblewski. It includes more than 30 professionals and has access to KPMG's international transfer pricing practice.
The team currently advises a large Canadian asset and fund manager on the transfer pricing aspects of its acquisition of a residential group, including the integration and adaptation of transfer pricing policy across four jurisdictions.
Partner Wroblewski joined the firm in august 2018, following four years as senior economist at Baker McKenzie and four years as a director at PwC Luxembourg.
Loyens & Loeff is known for operating a strong transfer pricing department across the Benelux region, offering advice on business model optimisation, profit allocation analysis as well as policy design and implementation. The Luxembourg team, led by partner Peter Moons, is also renowned for its specialism in providing transfer pricing advice on fund management structures, and for financial instruments. Moons' team in Luxembourg includes 10 transfer pricing professionals.
The team recently advised Jack Wolfskin on the TP aspects of its acquisition through a shareholder sale to American Callaway Golf. The TP advice covered the sale of the Luxembourg selling entity, the closing of the selling structure and the distributions to shareholders. The firm has also been involved in a number of bond issuances, including assisting on the senior secured notes issued for Brazilian client Centrais Elétricas de Sergipe by Goldman Sachs. The issuance was run through a Luxembourg special purpose vehicle, on which the firm advised on the necessary transfer pricing considerations.
TransFair Pricing Solutions is a transfer pricing boutique, established in 2017 and led by Vanesa Ramos Ferrin. She advises her clients on all aspects of transfer pricing documentation, policy analysis and creation, as well as providing benchmarking and cost sharing economic analysis. She also counsels clients with regard to transfer pricing audits and economic analysis for APA and MAP rulings.
Since its inception in 2018, TS&P has seen transfer pricing as a key area for the firm. The transfer pricing team is led by director Carlos Morales Ribas, who joined TS&P from Baker McKenzie in 2018. He is supported by one other specialist, associate Borja Martinez. The team is capable of analysing and designing transfer pricing policies, as well as conducting value chain analysis, developing financial structures with economic analysis, and representation in disputes as well as MAPs/APAs negotiation.
The firm recently advised two asset management firms on the integration of their activities by assessing the compliance of the split between the two in respect of their varied fund distribution channels and portfolio management activities, pertaining to the arm’s-length principle. The assessment led to the design and implementation of a new transfer pricing policy for the new fund, in order to ensure full compliance with the arm's-length principle.