The 2017 budget law has been published on 27 December 2016 in the official gazette. [endif] The new article 56bis and its complement, the Circular n°56/1-56bis/1, are giving new guidance for transfer pricing on intra-group financing activities. ADEQUATE SUBSTANCE (presence, know-how and activities) is a KEY ELEMENT under the new framework. [endif] This law aims at ensuring sustainability of financing vehicles in Luxembourg. [endif] These new measures entered into force on Jan

Intra-group financing activities will need more elaborated transfer pricing approach. Equity at risk definition will require a more detailed analysis. [endif] To perform/execute/review/monitor activities commonly found in financing/risk management entities, adequate staffing is requested. Boards and operations are concerned. The alignment of the local specialized resources/profiles (the substance) to the revenue generation is mandatory and is part of the justification of the