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Partner, Transfer Pricing, PwC Luxembourg Article 164ter (3), in line with Article 7 (2) (b) of ATAD 1, provides that an arrangement is to be regarded as “non-genuine” to the extent that the CFC would not have owned the assets, or would not have undertaken the risks, which generate all or part of its income, had it not been controlled by the Luxembourg taxpayer where “significant people functions” linked to those assets and risks, are both carried out and play an essential role in generating the controlled company’s income.

Partner, Transfer Pricing Leader, PwC Luxembourg The Luxembourg Inland Revenue is one of the three tax authorities in the Grand Duchy, along with the Indirect Tax Authority and the Customs and Excise Agency. Such documentation should be made available upon request to the Luxembourg tax authorities.

The main objective of the Luxembourg Inland Revenue is to implement the legislation related to direct taxation, such as: 1. determining and collecting direct taxes (personal income tax, corporate income tax, business tax, withholding tax on wages, salaries and pensions, etc.

Under implementation of the ATAD, the definition of a domestic permanent establishment (PE), codified in art.

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