Luxembourg Details Approach to Simplified Transfer Pricing Rules

April 16, 2026, 5:12 PM UTC

Luxembourg’s tax administration published guidelines Thursday for a streamlined approach to marketing and distribution activities under the OECD’s simplified transfer pricing rules.

The rules, known as Amount B, are part of the OECD’s 2021 global tax deal designed to simplify transfer pricing compliance for such activities, reduce disputes, and support more efficient resolution when disagreements arise.

The US and Singapore are the only other countries so far allowing companies to opt in to Amount B.

Transfer pricing is the valuation of transactions between affiliates; generally deals should be priced at arm’s length, comparable to deals between unrelated parties.

Luxembourg ...

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