Industrial groups have set up investment vehicles in Luxembourg to benefit from its extensive treaty network, the access to EU directives and the overall flexibility of the legal and tax environment offered by the country. Philippe Neefs and Sophie Boulanger of KPMG explain the transfer pricing aspects of this investment destination.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap