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 January 1st, 2017.
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 transfer pricing approach. The Square Finance can support you on this matter with flexible solutions.