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Luxembourg Introducing New Transfer Pricing Documentation Requirements and APA Procedures

12 April 2023

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Proposed Changes

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Luxembourg

Luxembourg's Minister of Finance has reportedly submitted a draft law in Parliament that introduces various tax changes. This includes, among other things, new rules regarding the preparation and submission of transfer pricing documentation. Currently, Luxembourg tax law only includes general requirements for taxpayers to disclose related-party transactions and document their compliance with the arm's length principle. The draft law would introduce specific obligations for taxpayers to prepare transfer pricing documentation in line with OECD standards (BEPS Action 13) and to submit the documentation upon request with a prescribed deadline. For this purpose, detailed requirements are to be issued through a...