This training programme, organised by ILA, with our Tax Partner, Oliver R. Hoor, as speaker, comprises of four modules which will provide participants with a 360° overview of the new tax environment in which Alternative Investments have to navigate.
More information on the all sessions here.
20 September (1:30pm to 3:30pm)
Module 1: Implementing alternative investments in the post-BEPS era: Considering the impact of new tax rules (ATAD1 & 2, MLI)
This training will be of significant importance for Non-executive directors 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.
More information on this first session can be found here.
20 September (4:00pm to 6:00pm)
Module 2: The importance of substance
This training will be of significant importance for Non-executive 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 characterized 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.
More information on this second session can be found here.
28 September (1:30pm to 3:30pm)
Module 3: Transfer pricing in the context of Alternative Investments
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 characterized by maximum transparency.
More information on this third session can be found here.
28 September (4:00pm to 6:00pm)
Module 4: The Mandatory Disclosure Regime (DAC6)
This training will be of significant importance for Non-executive 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. .
More information on this fourth session can be found here.