Atoz

Luxembourg

Address:
1B Heienhaff
Senningerberg L-1736
Luxembourg

+352 (0)26 940 1


Key contacts:

Managing Partner – Operations: Fatah Boudjelida
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Managing Partner: Keith O'Donnell
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Partner, Head of International & Corporate Tax: Romain Tiffon
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Partner, Head of Corporate Implementation: Jérémie Schaeffer
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Partner, Head of Corporate Finance: Christophe Darche
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Principal, Indirect Tax Team Leader: Thibaut Boulangé
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Partner, Head of Transfer Pricing: Oliver R. Hoor
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Quick facts:

Number of advisers: 105
Network memberships: Taxand
Languages: English, French, German, Luxembourgish


ATOZ Tax Advisers is a high-end independent advisory firm offering a comprehensive range of tax, transfer pricing and financial advisory services. We advise our clients on sustainable transfer pricing approaches that consider both tax and transfer pricing aspects and assist with the preparation of robust transfer pricing documentation mitigating tax risks linked to intra-group transactions.

Our transfer pricing expertise includes the determination of arm's length prices/remuneration in regard to:

  • Financing activities;
  • Intermediaries in financing transactions;
  • Interest rates on a wide range of debt instruments;
  • Fund management services;
  • Intra-group services;
  • Debt/borrowing capacity;
  • Valuation of tangible and intangible assets;
  • Attribution of profits to a permanent establishment and its head office.

We also assist with the preparation of Master Files.

Transfer Pricing 

Oliver R. Hoor

Partner, Head of Transfer Pricing 

oliver.hoor@atoz.lu 

 

Recent matter highlights: 

1. 

Our client acquired a US multinational group with business activities in the US and Europe through its Luxembourg investment platform. The investment was made through several Luxembourg companies which take a prominent role in the management of the group’s business activities and the funding of its operations around the globe. In this regard, a Luxembourg company has been taking on external debt of circa EUR 1bn which is on-lend to several group companies. 

ATOZ prepared all transfer pricing documentation necessary for Luxembourg tax purposes, including two transfer pricing reports determining the arm’s length remuneration for financing activities, a transfer pricing report determining an arm’s length remuneration for an entity performing on-lending activities and having the functional and risk profile of an intermediary as well as the determination of arm’s length interest rates for various debt instruments (interest bearing loans, convertible instruments).

2.

Our client was an asset manager managing several Luxembourg private equity funds through a Luxembourg management company advised by foreign advisory company. The funds were paying significant amounts of fund management fees to  remunerate the services of both the Luxembourg management company and the foreign advisory company. 

In this regard, it was necessary to determine an arm’s length remuneration for the Luxembourg management company. Given the functional and risk profile of the Luxembourg management company which was comparable to that of third party management companies, ATOZ applied a transfer pricing approach which relied on the CUP method. The transfer pricing analysis was documented in a comprehensive transfer pricing report. 

3.

Our client was an asset manager managing two Luxembourg real estate funds through a Luxembourg management company receiving advisory services from a foreign advisory company. Significant amounts of fund management services remunerated both the services of the Luxembourg management company and the foreign advisory company.

In this regard, it was necessary to determine an arm’s length remuneration for the Luxembourg management company and the foreign advisory company.