Luxembourg



World TP Reviews

Transfer pricing
Allen & Overy

The tax practice at Allen & Overy is made up of two partners and 16 other professionals. The group provides a full range of transfer pricing services for companies in Luxembourg carrying out relevant transactions. The team assists in the implementation and design of TP policy, determination, documentation, APAs and tax controversy regarding TP.

The team advised on numerous matters involving transfer pricing concerns. All clients remain confidential.

Arendt & Medernach

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.

All transfer pricing work remains confidential.

The firm recently hired four associates, Donjeta Beka, Lucile Dos Santos, Sarah Holtermann, and Franklin Lamouroux.

Baker McKenzie

The transfer pricing group at Baker Mckenzie is known for its globally coordinated approach to its transfer pricing work. It advises on a variety transfer pricing services including implementation, adjustments, documentation, and design.

All clients remain confidential.

The team welcomed Partner Diogo Duarte de Oliveira from Stibbe Luxembourg, as well as two counsels, Olivier Dal Farra and Delphine Danhoui, from Stibbe. Senior associates Lionel Ancion and Miguel Pinto de Almeida joined the firm as well as Tiphanie Grzeszezak, all from Stibbe Luxembourg.

Clément Konrad & Partners

The tax team at Clément Konrad & Partners is known for providing structuring, transactional tax advice and tax litigation. The group is engaged in providing transfer pricing policy to its clients compliant with OECD guidelines.

Over the research period, the team worked on numerous matters that involved transfer pricing considerations for designing transfer pricing policy. All clients remain confidential.

Clifford Chance

Clifford Chance’s tax presence is Luxembourg is focused within the areas of fund formation, real estate investment and transactions as well as local level litigation. The firm works with its tax advisers in various global offices to advise clients in the areas of international taxation and cross-border transactions. The firm advises on transfer pricing aspects for its clients. It ensures clients are complicit with current OECD transfer pricing guidelines. The Luxembourg tax department is led by partner Geoffrey Scardoni, who is assisted by counsel Maxime Budzin.

Over the research period, the team advised Rothschild Investment Management on placing transfer pricing arrangements when setting up its Luxembourg Platform. The team also advised Pictet Fund on understanding TP challenges.

The tax team welcomed senior tax adviser Kim Ngo from DLA Piper and associate Marine Mouchel Vallon from Linklaters during the research period.

Deloitte

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.

During the research period, the team advised on numerous innovative and complex matters. A highlight was the first bilateral APA between the UK and Luxembourg tax authorities to provide tax certainty related to exit tax triggered by Brexit-related restructuring. The group also advised on the full-on restructuring of transfer pricing policies for several major clients. All clients remain confidential.

The team grew with the addition of manager Mariana Cohen Margiotta and seniors Marie Althaus and Roxane Gallon.

Client feedback

“Very well organised and knowledgeable. They were very good at communicating with us as the client and also with the tax authority.”

“Ralf and his team were great to work with. Their approach was practical and they provided good insight into Luxembourg TP and how to manage our risks accordingly.”

“Great quality, availability for discussions and better understandings, flexible to find solutions better fitting to our business model than the mere standard.”

DLA Piper

DLA Piper operates a small Luxembourg tax team, headed by partner Jacques Wantz, which focuses its expertise on advising clients within the alternative investment field. It advises on all indirect and direct taxation advice for alternative investment funds, including fund set up, fund structure and transactions. The team also advises on transfer pricing, tax compliance and mutual agreement procedures.

All clients remain confidential.

The team welcomed Counsel Julie Hecklen from ING Private Bank. Senior associate Kim Ngo left the firm for Clifford Chance.

DSM Avocats à la Cour

The tax team at DSM Avocats à la Cour is composed of founding and managing partner Mario Di Stefano, partner Jérôme Bach and counsel Alex Pham. The group advises corporate clients on a wide variety of international transactions and investment structures.

All clients remain confidential.

Dupont Partners

Dupont Partners offers a full-service tax law department that can match the needs of local and international clients. The group covers all international transaction and structuring work, tax audit and litigation. The team provides transfer pricing studies and review.

All transfer pricing work remains confidential.

During the research period, the group hired of counsel Estelle Wanssy from Deloitte. The team also grew with senior associate Cathy Brugger from Van Den Bulke and of counsel Cristiano Bortolotti from Dentons.

KPMG

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.

During the past 12 months, the team provided coordination of tax due diligence, structuring and transfer pricing services for a major US private equity house following its acquisition of a major healthcare company. The team also advised on the transfer pricing aspects as part of an ISO readiness assessment for a client.

During the research period the team hired partner Henri Prijot from Deloitte and Partner Benedicte Moens-Colleaux from BMC Advisory.

Loyens & Loeff

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 firm handled an impressive multitude of different transfer pricing matters during the research period. A standout matter was the advice provided to Wirecard on the complex transfer pricing considerations of its €900 million investment by Softbank. Most clients remain confidential.

The firm hired associate Aline Nunes from EY, New York in April 2019.

Norton Rose Fulbright

Norton Rose possesses a global network of over 50+ offices. The transfer pricing department in Luxembourg provides planning, documentation and structuring of company and inter-company agreements, as well as APAs.

During the research period, the team advised Oxus Development Network on the transfer pricing considerations of a cross-border reorganization. All other clients remain confidential.

The group hired tax partner Florent Trouiller from Dechert. The team also welcomed tax associate Katherine Martineau. Tax partner Raquel Guevara left the firm for Warburg Pincus.

TransFair Pricing Solutions

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.

During the research period, the team advised Eurofins on intra-group financing loans that presented complex challenges. The group also performed a valuation analysis to determine marker value of tangible and intangible assets for FBM and Xylomen.

The team welcomed senior consultant Trang Tran in January 2020.

Client feedback

“Excellent work with precise timetable and top quality output.”

“Transfair Pricing Solutions did an excellent job in turning to practice advanced financial academic concepts in the construction of the transfer pricing methodology and its drivers in terms of pricing. They adequately advised and trained our teams, and ensured efficient follow up.”

“We had a real pleasure to work with Transfair Pricing Solutions. Vanessa is very professional, and she always answer all of our questions.”

“Straightforward, easy to work with, high technical level.”

TS&P

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.

During the research period the team at TS&P worked on numerous complex and innovative transfer pricing matters. All clients remain confidential.

Client feedback

“Solid technical knowledge, strong reactivity, reliability.”

“Very reactive and professional team.”