Michal Stepien

Michal Stepien

Principal Associate
Head of Transfer Pricing
Luxembourg
About

Michal is a tax practioner with significant international experience, particularly in strategic transfer pricing, financial transactions transfer pricing, and transfer pricing audits and litigation. His experience in both in-house roles and at a Big 4 firm, coupled with extensive international exposure, provides him with a nuanced understanding of the practical complexities inherent in multinational operations and managing diverse stakeholders.

He has successfully led and contributed to projects encompassing the resolution of tax controversies, tax planning, Value Chain Alignment (VCA), and tax-effective acquisitions, integrations, and reorganizations.

Areas of FocusTaxInvestment Funds

EXPERIENCE

Michal's relevant experience includes advising:

  • A leading U.S.-based global footwear company, on a complex cross-border internal reorganisation involving multiple jurisdictions.
  • The world’s leading professional services firm in risk, strategy, and people, on a complex internal reorganisation and related pre-litigation discussions with the Luxembourg tax authorities.
  • A leading U.S.-based global footwear company, on a complex cross-border internal reorganisation involving multiple jurisdictions.
  • A U.S.-based investment firm, in connection with the tax structuring of the establishment of a Luxembourg investment fund dedicated to direct lending strategies.
  • A leading Saudi Arabian investment manager, in connection with urgent Sharia-compliant re-financing for a real estate asset in Belgium, including the structuring of financing remuneration in compliance with transfer pricing requirements and Islamic finance principles.
  • A major investment adviser specializing in private debt for energy infrastructure, on the transfer pricing and tax structuring aspects of an additional private debt issuance transaction exceeding EUR70m, involving its Luxembourg platform.
  • A private real estate investor on the design and implementation of a multi-jurisdictional intragroup financing restructuring involving Luxembourg, Cyprus, Bermuda and Germany, with assets exceeding EUR 850 million, initially providing strategic tax and transfer pricing advice before supporting the full transactional execution.
Languages
  • Polish
  • English
  • French
Education
  • Warsaw School of Economics, Master's Degree in Finance & Banking (specialization Management Accounting), 2003
  • Wyższa Szkoła Informatyki i Zarządzania (Computer Science and Management College), Bachelor’s Degree in Computer Science, 1999

Publications and media

  • “Debt capacity analysis across Europe: emergence of a new TP reality”, ITR, (co-authored with Karolina Ibranyi-Matkovits), October 2023
  • “Debt capacity under review across Europe – emergence of a new transfer pricing reality”, AGEFI Luxembourg, (co-authored with Karolina Ibranyi-Matkovits), October 2023
  • “Managing Liquidity in the Time of High Interest: Transfer Pricing Considerations”, AGEFI Luxembourg, (co-authored with Cristina Blindu and Joep Hoksbergen), January 2023
  • “Dimension of Substance – interplay between Transfer Pricing and Controlled Foreign Corporation Rules”, AGEFI Luxembourg, (co-authored with Karolina Ibranyi- Matkovits), January 2022

Seminars

  • "Emerging Trends in Transfer Pricing: Insights from Industry Practitioners", LTPA Transfer Pricing Trends Conference, 2025
  • "Luxembourg PE Toolbox", Luxembourg Private Equity & Venture Capital Association Seminar in Warsaw, 2024

Memberships and Affiliations

  • Founding member of the Luxembourg Transfer Pricing Association

My latest insights

Publication

Landmark Luxembourg Ruling on Proving U.S. Permanent Establishments

10 October 2024 .3 minute read

Publication

Unlocking the Key Transfer Pricing Aspects in Asset Management

12 September 2024 .6 minute read

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Connect

Phone

+3522629042072
(Work, Luxembourg)
+352691196180
(Mobile)