Analyse et documentation des prix de transfert dans une multinationale au Luxembourg

Abstract

Circuit Foil group produces and sells copper foil all over the world. The headquarters, Circuit Foil Luxembourg, is located in Grand-duchy of Luxembourg. Circuit Foil Luxembourg has three subsidiaries located in USA, Hong Kong and China. It also has one branch in Canada. Transfer pricing is defined in the Principles of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Transfer pricing is the price at which a company transfers goods or offers services to an associated company. Transfer pricing at arm's length is equal to the transfer pricing that independent parties would have accepted for the same transaction on the market. To achieve this arm's length principle, the transaction made by the controlled company would be compared with the transaction of independent companies. The application of the arm's length principle helps to conduct a functional and benchmarking analysis in order to compare the controlled transaction with independent transactions. Several steps are necessary to perform this project. Firstly, a good command of the theory of transfer pricing is needed in order to fix the price of the intragroup transaction between the company and its subsidiaries. Secondly, you have to analyze the actual transfer pricing applied within the group. Thirdly, a benchmarking analysis has to be conducted. Finally, you can apply the selected markup on each subsidiary as well as the tax impact of the proposition. This project gives more guidance to the group Circuit Foil on how to set a fair transfer pricing and how to prepare transfer pricing documentation.