Transfer Pricing aspects of Non Regulated Private Equity Structures
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Transfer Pricing aspects of Non Regulated Private Equity Structures

courseType Technical Skills, Financial Sector

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As an advantageous location for investment vehicles due to a flexible and efficient tax environment, a considerable number of non-regulated private equity structures have been implemented in Luxembourg. Increased investor requirements as well as international focus on transfer pricing have resulted in the issuance of local transfer pricing guidance by the Luxembourg tax authorities. Initial regulations apply mainly to related companies engaged in lending activities financed by borrowings. Furthermore, additional transfer pricing matters are likely to become of increased importance in the non-regulated structures. Transfer pricing is, moreover, one of the most powerful tools to manage a multinational’s group effective tax rate. In this context, PwC's Academy is pleased to present the different aspects of transfer pricing in non-regulated private equity structures, including a comprehensive overview of the impacts transfer pricing may have on multinationals as well as structuring opportunities for tax optimisation. Theory, real life examples and practical exercises are combined during the training.


The objective of this course is to understand the key aspects of transfer pricing and the related tax considerations in non-regulated private equity structures. Upon completion of the course, participants will be able to:
  • Have a better understanding of the Luxembourg transfer pricing framework
  • Identify and address the key risk areas in transfer pricing in the non-regulated environment
  • Appreciate the structuring opportunities provided by transfer pricing
  • Apply in practice the examples analysed during the training


  • Introduction
  • Basic Concepts of transfer pricing
       - The arm’s length principle
       - Functional Analysis
       - OECD methods
       - The importance of documentation
  • Luxembourg transfer pricing guidelines
       - Background  and Scope of Circular LIR 164/2 bis
       - Determination of arm’s length remuneration
       - Transfer pricing requirements in the non-regulated structures
       - Main considerations
  • Transfer pricing structuring opportunities
       - Tax optimisation opportunities
  • Conclusion

Target audience

  • Accountants of Private Equity structures established in Luxembourg
  • Accountants of investment banks and custody involved in Private Equity
  • Chartered accountants and fiduciary employees
  • Financial controllers and analysts
  • Internal and external auditors
  • Tax experts


This training is coordinated by Begga Sigurdardottir, Transfer Pricing Partner in PwC Luxembourg as well as by Marc Rasch, Transfer Pricing Director in PwC Luxembourg. The training will be presented by directors and managers who are specialised in this subject.



Number of participants

Limited to 20 participants, to ensure good interactivity


0.5 day

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