In a Circular issued by the Cyprus Tax Authorities on 30 June 2017, new transfer pricing rules have been implemented for companies carrying out intra-group financing activities. The Circular is effective immediately and replace the former Minimum Margin Scheme regime. The Circular contains requirements regarding substance, risk/equity and arm’s length compensation.

The new rules for intra-group financing companies in Cyprus are largely similar to the rules implemented in Luxembourg at the beginning of this year. 

On July 10, 2017 the OECD released the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (Transfer Pricing Guidelines).

On June 22, 2017 the OECD released two public discussion drafts, containing guidance on its Final Reports on Base Erosion and Profit Shifting (BEPS) of October 2015. Both discussion drafts replace earlier draft versions released for public comment in July 2016.

On 27 December 2016, the Luxembourg Tax Authorities ("LTA") issued new guidelines by means of the issuance of Circular L.I.R. no. 56/1 – 56bis/1 ("the Circular") dealing with the Luxembourg tax treatment applicable to Luxembourg companies engaged in intra-group financing transactions.

T/A economics' partner WTS was distinguished in two areas at this year’s International Tax Review (ITR) European Awards Ceremony, which took place on May 18 in London. WTS Global was honored with the award for European Indirect Tax Firm of the Year 2017 and WTS Germany was crowned Germany‘s Tax Firm of the Year 2017.

On April 6th, the Organization for Economic Cooperation and Development (OECD) launched additional guidance for tax administrations and MNE Groups alike on the implementation of Country-by-Country (CbC) reporting (BEPS Action 13).

Op de ministerraad van 2 december 2016 bereikten de regeringspartijen een akkoord over een nieuwe aftrek voor innovatie-inkomsten. Deze is tot stand gekomen onder invloed van het BEPS-actieplan dat lidstaten verzocht om hun wetgeving in lijn te brengen met de richtlijnen van de OESO. De nieuwe wet treedt retroactief in werking vanaf 1 juli 2016.

... as the BeNeLux alternative for transfer pricing and valuation services, with a distinct approach.

We are pleased to announce the launch of T/A economics, a joint venture between Tivalor, a Belgium and Luxembourg based economist boutique, specialized in transfer pricing and valuations, and the Amsterdam based transfer pricing team of Atlas tax lawyers. Combined, the former teams of Tivalor, business & legal economics, and Atlas, transfer pricing will be able to offer their clients with a distinct, integrated, borderless service approach throughout the BeNeLux, and interconnectivity globally through its partnership with the WTS Global network, present in over 100 countries. T/A economics’ credo is to create exponential value for its clients through the sharing of experiences.

1. Introduction

The Luxembourg direct tax authorities issued on 27 December 2016 new guidelines by means of the issuance of Circular L.I.R. no. 56/1 – 56bis/1 (hereinafter the “Circular”) which deals with the Luxembourg tax treatment applicable to Luxembourg companies engaged in intra-group financing transactions. The Circular details the application of the arm’s length principle to such transactions which principle has been codified in the Luxembourg direct tax law via articles 56 LIR and a newly introduced article 56bis LIR (which will apply as from 1 January 2017). Click here for an English translation of the Circular.