This training programme, organised by ILA, includes a series of four webinars that will provide participants with a 360-degree view of the new tax environment in which alternative investments must navigate, presented by our Tax Partner and Head of Transfer Pricing, Oliver R. Hoor.
Module 1 - Implementing alternative investments in the post-BEPS era: Considering the impact of new tax rules (ATAD 1 & 2, MLI)
21 September
This training will be of significant importance for independent directors that need to have a clear understanding of the new tax environment applicable to Alternative Investments such as Private Equity, Private Debt, Real Estate and Infrastructure. This course will provide an overview of new tax rules such as the interest limitation rules and the hybrid mismatch rules that have been implemented across Europe following the OECD BEPS project. As such, participants will learn about the points of attention that need to be considered when implementing or maintaining cross-border investments.
Course highlights
- Typical investment structures
- Interest estimation rules
- Hybrid mismatch rules
- Reverse hybrid mismatch rules
- General anti-abuse rule
- Tax treatment in the investments jurisdiction
More information here.
Module 2 - The importance of substance
28 September
This training will be of significant importance for independent directors that need to have a clear understanding of substance requirements in international taxation. While substance has always been important for Luxembourg companies that frequently operate in a cross-border context, the OECD Base Erosion and Profit Shifting (“BEPS”) Project only elevated their importance in an international tax environment that is characterised by total transparency. The more recent initiative of the EU Commission in regard to shell entities is evidence that the topic of substance will remain high on the agenda.
Course highlights
- Substance requirements
- Limits of anti-abuse legislation
- Organisation of substance
More information here.
Module 3 - Transfer pricing in the context of alternative investments
19 October
This training will be of significant importance for independent directors that need to have a clear understanding of the relevance of transfer pricing and related documentation when it comes to tax risk management. While transfer pricing has been a hot topic in Luxembourg since years, the OECD Base Erosion and Profit Shifting (“BEPS”) Project only elevated its importance in an international tax environment that is characterised by maximum transparency.
Course highlights
- Overview of the Luxembourg transfer pricing landscape
- Analysis of the typical controlled transactions in Luxembourg
- The Luxembourg Transfer Pricing Circular
- Tax risks in relation to transfer pricing
- Transfer pricing documentation requirement
- Best practice recommendations
More information here.
Module 4 - The mandatory disclosure regime DAC6
26 October
This training will be of significant importance for independent directors that need to have a clear understanding of the mandatory disclosure regime (“MDR”) of potentially aggressive tax planning schemes in the EU (covering cross-border arrangements since June 2018), how to determine reportable cross-border arrangements in practice and how taxpayers (and intermediaries) may ensure compliance.
This training is also presented by Romain Tiffon, Tax Partner, and Fanny Bueb, Tax Principal.
Course highlights
- Analysis of the MDR (DAC6)
- Developing a pragmatic approach
- The implementation of DAC6 across Europe: A snapshot
- Practical experience in regard to new reporting obligations
More information here.