Antonio A. Weffer

Antonio A. Weffer

Tax Principal
Baker & McKenzie Luxembourg
Not admitted to practice law in this jurisdiction

Biography

Antonio A. Weffer is a tax principal in Baker McKenzie's Tax Practice Group and the head of the firm's transfer pricing practice in Luxembourg. He advises multinational enterprises, financial institutions, asset managers, private equity houses and international groups on the full spectrum of transfer pricing matters, including intra-group financing, value chain analysis, supply chain models, benchmarking, documentation, transfer pricing audits and dispute resolution.

He has over 25 years of experience handling complex financial and non-financial multinational enterprises, cross-border transactions, reorganizations, mergers and acquisitions across a range of industry sectors.

Antonio is regularly recognized by leading legal directories for his Transfer Pricing and Tax expertise.

Practice Focus

Antonio’s profile is centred on transfer pricing, with experience covering the design, implementation, documentation and defence of transfer pricing policies for complex multinational groups. His work includes intra-group financing, financial transactions, functional and value chain analyses, benchmarking, valuation support, supply chain alignment, transfer pricing aspects of cross-border reorganizations and M&A, and audit defence in contentious matters. He assists clients in aligning their transfer pricing models with business operations, governance, substance and evolving OECD standards, while supporting both planning and controversy needs across multiple jurisdictions and industry sectors.

Representative Legal Matters

  • Advised a global technology group on the design and documentation of a multi-jurisdictional transfer pricing policy for intercompany loans and cash pooling arrangements, including credit rating analysis, yield-spread benchmarking and arm’s length pricing of financing flows across EU and non-EU jurisdictions.
  • Assisted a multinational group in a high-value cross-border transfer pricing controversy concerning intra-group financing arrangements, including the defence of borrower credit ratings, interest rates and prepayment penalties before tax authorities and in litigation-oriented proceedings.
  • Advised a multinational group on the design and implementation of an OECD-aligned transfer pricing framework for Luxembourg asset management and treasury entities, including FAR/KERT analysis, multi-layer remuneration models and benchmarking support in the context of evolving transfer pricing rules in a key non-EU jurisdiction.
  • Advised a global digital payments group on the fair market value analysis of a cross-border intragroup equity transfer involving a regulated payments entity, including DCF valuation, market-based corroboration, functional analysis and audit-ready transfer pricing support.
  • Advised the world’s largest infrastructure asset manager, with growing infrastructure and social infrastructure portfolio of more than USD 129 billion under management, on the restructuring of the financing/capital structure of one of its major fund structures with investments in multiple European countries and total commitments of GBP 2.7 billion.
  • Advised a unique highly renowned industrial designer looking for integrated transfer pricing solution to align the highly complex, competitive and continuously evolving value chain model of the industrial designing industry.
  • Assisted the Luxembourg management company of an international asset management group licensed under the UCITS regulation, in the context of the tax audit of its intra-group transactions, concluded with related companies located in Switzerland, Germany, Italy, France and Austria.
  • Assisted a New York-based distressed-focused hedge fund investment adviser in testing the arm's length nature of a total interest expense in the context of a multifactorial debt instrument, through which investments were mainly made in Western Europe.
  • Assisted a leading European financial services firm, specialised in equity brokerage, equity capital markets and asset management, in the restructuring process of their asset management division, designing a new business model and functional structure for the entities involved.
  • Advised clients on transfer pricing models involving intra-group financing, functional and value chain analysis, benchmarking, documentation, supply chain alignment, transfer pricing aspects of reorganizations and audit defence across multiple jurisdictions and business models.
  • Advised multinational groups on transfer pricing documentation and economic analyses, including benchmarking studies, functional analyses and support for intra-group financing, services, royalties and value chain models.
  • Assisted clients in transfer pricing audits and controversy matters, including audit defence strategy, responses to tax authority enquiries and support in cross-border dispute resolution.

Professional Honors

Firm rankings

  • ITR World Tax 2026: Tier 1 in Transactional Tax, Tax Controversy and Transfer Pricing
  • Legal 500 EMEA 2026: Tier 1 in Tax
  • Chambers Europe 2026: Band 2 in Tax
  • Leaders League 2026: Leading in Tax Litigation, Corporate Tax and Transfer Pricing
  • ITR Awards 2024: Luxembourg Transfer Pricing Firm of the Year
  • ITR Awards 2023: Luxembourg Tax Disputes Firm of the Year

Individual rankings

  • Legal 500 EMEA 2026: Leading Partner in Tax
  • Chambers Europe 2026: On Spotlight in Tax
  • ITR World Tax and Transfer Pricing Guides 2026: Highly regarded in Transfer Pricing
  • Leaders League 2025: Leading Partner in Transfer Pricing and Corporate Tax

Professional Associations and Memberships

  • Luxembourg Transfer Pricing Association (LTPA) member
  • ALFI Digital Taxation and Transfer Pricing working groups member
  • AMCHAM Tax Committee working group member
  • International Fiscal Association (IFA) - Luxembourg Branch member
  • International Bureau of Fiscal Documentation (IBFD)
  • International Tax Center Leiden University – Holland
  • International Latin American Tax Law Association (ILADT) – Venezuelan Branch (AVDT) - Member
  • Venezuelan Tax Law Association (AVDT) and Financial Law Association - Member
  • Camera di Commercio Italo-Lussemburghese (CCIL) member
  • British chamber of commerce (BCC) member
  • International Bar Association member (IBA) member
  • Institut Luxembourgeois des Administrateurs (ILA) member
  • Luxembourg association of family offices (LAFO) member
  • Luxembourg Private Equity and Venture Capital Association member
  • The Luxembourg Banker's Association member
  • The Association of the Luxembourg Fund Industry member
  • Cámara de Comercio de España en Bélgica y Luxemburgo member
  • Caracas and Miranda State Bar - Member
  • International Taxation in ESAN School of Business Diploma – Lima Peru - Professor

Education

  • Leiden University (LL.M. International Taxation) (2002)
  • Universidad Metropolitana (MS Taxation and Management) (2000)
  • Universidad Santa Maria (MS Tax Law and Public Finance) (1998)
  • Universidad Santa Maria (LL.B.) (1994)

Languages

  • English
  • French
  • Italian
  • Spanish
  • Co-author: Análisis de los Comentarios 2025 de la OCDE/ Analysis of the OECD’s 2025 Commentary, Universidad Central de Venezuela, July 2026
  • Author: PepsiCo Case: Hidden Royalties, the DPT, and the Limits of Australian Anti-Avoidance Doctrine, AGEFI, May 2026
  • Author: Why Royalty Disputes Are Rising in Global Taxation: PepsiCo Case, Bloomberg Tax, May 2026
  • Co-author: Trends & Developments, International Tax Guide 2026, Chambers and Partners, May 2026
  • Co-author: Le contentieux fiscal en hausse au Luxembourg, Forbes Luxembourg, November 2024
  • Co-author: Luxembourg Pillar 2 law to be amended, ITR, July 2024
  • Co-author: Transfer Pricing and Intra-Group Financing, IBFD, May 2024
  • Co-author: Interactions between transfer pricing and customs rules further to the Hamamatsu case: a potential turmoil in Luxembourg? ITR & AGEFI, May 2023
  • Author: Las interacciones entre el IVA y los precios de transferencia en una economía cada vez más digitalizada, XXI Jornadas Latinoamericanas de Derecho Tributario, Guatemala, October 2022
  • Author, Luxembourg chapters “Law and Practice” and “Trends and Developments”, Chambers Global Transfer Pricing 2021, April 2021
  • Contributor, Chambers Transfer Pricing 2021 Global Practice Guide – Luxembourg chapter, April 2021
  • Author: Overview of two recent Luxembourg transfer pricing case laws: if you are on time, you are too late, Revue générale de fiscalité luxembourgeoise, November 2020
  • Author: Reconsidering the finance function of digital companies, International Tax Review – TP Supplement, April 2020
  • Author: BEPS Interest Expense Deductions, PaperJam, December 2016