People

Ralf Heussner

Partner | Financial Services Tax/ Transfer Pricing

Ralf Heussner

20 Boulevard de Kockelscheuer

L-1821 Luxembourg

Luxembourg

Luxembourg

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Ralf is a Financial Services Partner with Deloitte based in Luxembourg with an extensive international track record of over 18 years’ experience advising clients on transfer pricing, international tax and tax controversy. Ralf is co-leading Deloitte`s transfer pricing service offerings for the Financial Services sector globally covering the asset management sector.

Ralf focuses on the financial services sector and worked for many of the key players in the asset management (traditional and alternative), banking and insurance sectors during his tenure in Tokyo, Hong Kong, Frankfurt and Luxembourg. His experience covers a broad range of complex and global engagements on tax planning, restructurings, operationalization, documentation and tax controversy. He worked on more than 35 Advanced Pricing Agreements (APAs) and numerous high profile controversies on local and competent authority level with tax authorities in the US, Japan, China, Singapore and across the EU.

Ralf`s financial services related experience covers a wide range of topics along the transfer pricing life cycle ranging from planning and policy development, implementation/operationalization, restructurings, documentation, tax provision/risk reviews and audit defense/controversy related work. Specific examples across the asset management, banking and insurance sectors include:

  • Transfer pricing issues of cross-border distribution, investment management, administration and fund production in the asset management sector using fee splits (incl. benchmarking approaches using Lipper/Mercer) and profit splits;
  • Consideration for the unique role of regulated management companies under the UCITS/AIFMD regime and benchmarking approaches using third party ManCo data;
  • Tax impact of regulatory developments (esp. Basel) and increased liquidity/capital requirements on determination of free capital for banking branches and funds transfer pricing (FTP) for pricing the provision of liquidity;
  • Attribution of financial assets, profits and branch capital to permanent establishments in banking and insurance sector based on the Authorized OECD Approach (AOA);
  • Tax treatment and BEPS impact on core banking transactions covering global trading, capital markets and underwriting, investment banking, loan origination and syndication, securities lending, custody banking and sales credits;
  • Transfer pricing approaches for reinsurance and captive insurance arrangements including substance considerations and benchmarkings;
  • Tax treatment of intangibles covering trademarks and technology and guarantees; and
  • Intercompany services and management activities in the financial service.
  • In addition, Ralf also worked for various non-FS clients on topics such as IP planning, the design of procurement, R&D/cost sharing, manufacturing, sales and distribution as well as treasury (loans, cash pooling, captive insurance and guarantees) related activities.

Ralf holds a MBA / Degree in Economics from SDA Bocconi School of Management in Milan, Italy and has also studied at the Wharton Business School in Philadelphia, USA and International University of Japan.

Ralf Heussner