The Luxembourg Transfer Pricing Association (LTPA) held its first Transfer Pricing Congress on 2 October 2025, bringing together more than 300 participants representing multinationals, funds, banks, tax authorities, academia, and professional associations from Luxembourg and ten other jurisdictions.
The Congress was opened by Vanessa Ramos Ferrin, President of the LTPA, who in her speech highlighted the association’s rapid growth and the increasing importance of collaboration within the transfer pricing community. Since its creation, the association has grown from 22 to 70 members and established partnerships with 11 professional associations. She thanked the 25 sponsors and supporters who made the event possible and emphasized LTPA’s mission to serve as a platform for dialogue, technical exchange, and the development of best practices in Luxembourg.
This Congress also confirms Transfair Pricing Solutions’ broader impact on the Luxembourg transfer pricing landscape. Under Vanessa Ramos Ferrin’s leadership, the firm initiated and actively supported the creation of the Luxembourg Transfer Pricing Association (LTPA), now the country’s principal platform for professional dialogue, technical cooperation, and the development of best practices in transfer pricing.
The program was structured around four perspectives, Policy, Technology, Disputes, and Cooperation, each addressing a core dimension of transfer pricing in a changing global environment. The opening remarks also welcomed the creation, as of 1 October 2025, of the Transfer Pricing Competence Center within the Luxembourg Tax Authorities, coordinated by Mr. Marc Baumann, as an important step toward strengthening expertise and consistency in transfer pricing administration.
Policy developments and economic environment
The first session addressed key local and global policy developments shaping transfer pricing practices. The discussion covered legislative and economic changes introduced in 2025 to enhance Luxembourg’s competitiveness, the growing role of transfer pricing in foreign tax audits, and the increasing involvement of senior management in transfer pricing decisions.
Speakers also reviewed sectoral and international developments, including challenges in the German and European automotive industries, the continuing implementation of Pillar I and Pillar II, and international reactions to shifts in the global reform agenda. Other topics included the influence of high inflation and rapid technological advances, particularly artificial intelligence on transfer pricing analyses and profitability assessments.
The session concluded by stressing that these developments require tax and finance teams to be adaptable and proactive in anticipating regulatory change.
Technology and tools
This session examined how technology is transforming operational transfer pricing. Polling among attendees showed that automation now supports the preparation of local and master files, recurring calculations, real-time monitoring of intercompany transactions, and anomaly detection. Tools also contribute to consistency across jurisdictions, documentation updates, and audit preparedness.
Speakers discussed challenges in integrating tools with existing systems, maintaining data quality, and ensuring cooperation between tax and non-tax teams. The conversation on artificial intelligence focused on how AI can make transfer pricing processes faster and more efficient, while underlining the need for governance and transparency. Reference was made to the September 2025 Bosco decision of the Spanish Supreme Court concerning algorithmic transparency and fundamental rights, as a reminder of the importance of oversight when using automated tools.
Case law and procedural developments
The next session provided an overview of procedural matters from Luxembourg’s administrative courts, focusing on three key topics: the probative value of transfer pricing documentation, the presumption of the arm’s-length principle, and the importance of exchanges with the tax administration.
Recent judgments illustrated how courts assess substance-over-form issues, the treatment of shareholder loans, and the obligation to update analyses when conditions change. One decision confirmed that a shareholder loan qualified as debt and that notional interest deductions were admissible, as the tax administration had not refuted the taxpayer’s analysis. Another judgment emphasized the need to revisit benchmarks when a borrower’s financial situation evolves, while earlier case law reaffirmed the importance of robust comparability and timely documentation.
Disputes and cooperation
A session dedicated to managing transfer pricing disputes presented the available mechanisms for avoiding and resolving double taxation. These include unilateral, bilateral, and multilateral advance pricing agreements, mutual agreement procedures under treaties and EU frameworks, and cooperative programs such as the OECD International Compliance Assurance Programme and the European Trust and Cooperation Approach.
Key areas of focus identified in practice included documentation gaps, inconsistencies between analyses and actual functions, changes in structures, and audit settlements.
LTPA best-practice initiative
The final part of the Congress presented LTPA’s ongoing best-practice initiative. Following a member consultation launched in December 2024, sixteen key transfer pricing topics were identified, and two priority areas selected: Transfer Pricing Documentation and Credit Rating Determination.
Two working groups of ten professionals each, representing both in-house and advisory perspectives, were created in January 2025. They have engaged with 11 associations and policy-making and regulatory-controlling parties. Their work involves developing “Working Group Insights” papers, consulting stakeholders, and issuing best-practice statements or white papers.
The documentation group discussed the frequency of transfer pricing documentation updates, noting that while Luxembourg law does not set a specific requirement, the OECD recommends regular review and revision in response to material changes. The credit rating group highlighted the importance of reliable credit analyses across industries such as investment, real estate, aviation, and other sectors involving intragroup financing.
Looking ahead
The Congress concluded with the next steps for the working groups, which will share draft results with members for review before publication. LTPA also announced future community events, including a New Year networking gathering and the 2026 Transfer Pricing Forum for Investment Funds.
Through these discussions, the 2025 LTPA Transfer Pricing Congress demonstrated the strong momentum of Luxembourg’s transfer pricing community and its collective commitment to fostering clarity, collaboration, and best practices in an evolving international landscape.
About TransFair Pricing Solutions
TransFair Pricing Solutions is a Luxembourg-based transfer pricing advisory firm providing strategic, economic, and documentation services to multinational groups and investment structures. The firm is committed to technical excellence, transparency, and cooperation, contributing actively to the development of Luxembourg’s professional ecosystem through initiatives such as the Luxembourg Transfer Pricing Association (LTPA).
Media and client contact
For further information, please contact:
Vanessa Ramos Ferrin
Managing Director, TransFair Pricing Solutions
📧 v.ramos@tfps.lu
🌐 kwww.tfps.lu
