Over the next few months, Fanny Bueb - Tax Director, will be speaking during a series of trainings at the House of Training, covering various topics as detailed below:
- Transfer Pricing in Luxembourg
8 March & 4 October 2022
- Introduction to transfer pricing
- The arm’s length principle
- The OECD Transfer Pricing Guidelines
- Luxembourg transfer pricing rules and practices - Transfer pricing methodologies
- Comparability analysis and data base researches
- Common transfer pricing approaches applied in Luxembourg (financing activities, interest rates, intra-group services, fund management services, etc)
- Transfer pricing documentation and tax risk management
- Transfer pricing adjustments
More information here.
- Luxembourg Implements the Mandatory Disclosure Regime (DAC6): Moving towards DAC6 Readiness
15 March 2022
- Introduction
- Design principles and main objectives of mandatory disclosure regime
- Overview of the new disclosure regime
- Definition of tax intermediaries
- Reportable arrangements
- Information to be reported
- Reporting responsibilities
- Competing reporting obligations
- Timing aspects
- Penalties for non-compliance
- Analysis of the hallmarks that may trigger reporting obligations
- Understanding of the main benefit test and its importance in the new reporting regime
- Determining reportable cross-border arrangements
- Case studies
More information here.
- Implementation of ATAD 2 into Luxembourg Tax Law - Analysing the Impact on Alternative Investments and Multinationals
26 April & 6 Septembre 2022
- Overview of the Luxembourg tax reform
- Types of hybrid mismatch arrangements targeted by the new rules
- Hybrid mismatches (hybrid financing instruments, hybrid entities, hybrid permanent establishments, etc.)
- Reverse hybrid mismatches
- Tax residency mismatches - Mechanism of the anti-hybrid mismatch rules
- Limits of the scope of the new rules
- Case studies
More information here.
- Structuring Alternative Investments (Private Equity, Real Estate,.) in the post-BEPS era via Luxembourg
16 May & 20 Septembre 2022
- Overview of Alternative Investments structures via Luxembourg
- The OECD BEPS Project and related actions at EU level
- BEPS measures and their impact on Alternative Investment structures
- Determining and organizing the right level of substance
- Optimizing set-ups in the new international tax environment
- Structuring aspects
- The importance of arm’s length conditions and transfer pricing documentation
More information here.
Past events in 2021
- 2 June - Luxembourg Implements the Mandatory Disclosure Regime (DAC6): Moving towards DAC6 Readiness
- 8 & 10 June - Transfer Pricing in Luxembourg
- 6 September - Structuring Alternative Investments (Private Equity, Real Estate,…) in the post-BEPS era via Luxembourg
- 7 October - Transfer Pricing in Luxembourg