François Tréhorel
Associate
Luxembourg
François Tréhorel
Associate
Luxembourg
Contact details
François advises on transfer pricing and international tax law, predominantly in the context of cross-border transactions, with a focus on the tax structuring of investment funds and investment platforms.
He has experience in documenting intra-group financing activities in compliance with the Luxembourg domestic regulations and OECD Transfer Pricing Guidelines, as well as structuring and designing transfer pricing policies for various actors in the Luxembourg financial sector. He also has substantial experience in transfer pricing aspects involving multinational groups across various sectors.
He joined Allen & Overy in 2021.
Qualifications
Professional
Related articles
Publications: 01 March 2024
Amount B or not to be? The OECD’s Pillar One Amount B report
The application of the arm's length principle (ALP) is not always easy or free from conflict between taxpayers and tax authorities and this is especially true for countries with low resources and…