Insights · Tax

Transfer pricing in Luxembourg for small and mid-sized groups

Loans from the family holding, management fees, royalties and guarantees: what Luxembourg expects from small groups, when documentation is required and where hidden dividends start, with a check of your flows.
Check my flows ↓

Reading time5 minutes
TopicTransfer pricing
Rules as ofOctober 2026
AuthorAlexander Baranov
The short version

Every Luxembourg company must price related-party transactions at arm's length and justify them on request. Financing companies need equity at risk and local decision-makers; a 2% after-tax return is the safe harbour for pure intermediaries. Routine services at cost plus 5% are accepted. Overpayments to shareholders are hidden dividends with 15% withholding. Formal master and local files are for large groups.

01 · The rule

Transfer pricing applies to small groups too

Luxembourg's arm's length rule applies to every transaction between related companies, whatever their size: a loan from the family holding, a management fee from the parent, a royalty to a sister company. Large groups file master and local files; small groups need agreements and a short pricing rationale they can produce when asked.

Article 56bis

Arm's length

Prices between related parties must match what independent parties would agree.

2016 circular

Financing companies

Equity at risk, substance, 2% after-tax safe harbour.

5% mark-up

Low value services

Cost plus 5% is accepted for routine support.

Hidden dividend

15% withholding

Overpayments to shareholders are taxed twice.

02 · Flows

The flows in a small Luxembourg group

FlowWhat tax inspectors checkTypical fix
Loan to a subsidiaryRate, security, ability to repay, equity at riskRate benchmark, written terms
Loan from the shareholderExcessive interest, debt-to-equityMarket rate, documented need
Management feesReal services, cost base, mark-upCost plus 5%, timesheets, agreement
RoyaltiesWho developed the IP and whereSubstance at the IP owner
GuaranteesReal benefit to the borrowerFee only for explicit support
In a small group, transfer pricing is rarely about complex models. It is about a signed agreement and a reason for the number.
03 · Your case

Check your intra-group payments

Tick all flows that apply.

Check your intra-group payments in Luxembourg

Tick your flows and answer four questions. You get the documentation level and the risk points.

Which intra-group flows does the company have?
Written agreements and a pricing file?
Who is the counterparty?
Substance for financing or IP
Net interest expense a year
Need intra-group agreements and a pricing file?We draft the agreements, set arm's length rates and fees with our transfer pricing partners, and keep the file ready for the tax office.
Get a quote
01Every size

Arm's length applies to all related flows.

02Financing needs substance

Equity at risk and local decisions.

035% for routine services

Cost plus, documented.

04Overpay a shareholder

15% withholding on the excess.

04 · FAQ

Transfer pricing in Luxembourg: frequent questions

Does a small Luxembourg company need transfer pricing documentation?

Every Luxembourg company must deal at arm's length and be able to show it on request. Formal master and local files are aimed at large groups; a 2023 bill sets the line at EUR 100 million turnover or EUR 400 million balance sheet.

What are the Luxembourg rules for intra-group financing companies?

The 2016 circular requires equity at risk matching the functions, and qualified staff and decisions in Luxembourg. A pure financing intermediary earning a 2% after-tax return on equity is accepted without further analysis.

What management fee mark-up is accepted in Luxembourg?

For low value-adding services, cost plus 5%, in line with the OECD simplified approach.

What is a hidden dividend in Luxembourg?

An advantage given to a shareholder through non-arm's length prices, such as excessive interest or fees. It is not deductible and carries 15% withholding tax.

Is interest deduction limited in Luxembourg?

Net interest expense above EUR 3 million is deductible only up to 30% of tax EBITDA, under the EU anti-avoidance directive.

Your structure

Need your intra-group pricing in order?

We draft intra-group agreements, set arm's length rates and fees with transfer pricing partners and keep the file ready for an audit.