Analysing the impact of the new hybrid mismatch rules (ATAD 2) on Alternative Investments

This course is part of a 4-Module training program, providing participants with a 360-degre360-degree overview of the new tax environment in which Alternative Investments have to navigate.  Please follow the link to the full program: Alternative investments in the post-BEPS era - Training program

This training will be of significant importance for independent directors who need to clearly understand the new hybrid mismatch rules (ATAD 2) that may, if applicable, have a severe impact on the tax profile of Alternative Investments in Luxembourg. This course will provide an overview of the scope and limits of the hybrid mismatch rules and consider practical solutions for managing their impact in practice.

The main features of the program are:

• Mechanics of the hybrid mismatch rules
• Analysing the impact of ATAD 2 on Alternative Investments (Private Equity, Real Estate, Infrastructure, ...) 
• Considerations regarding ATAD 3 (the "Unshell Directive")