Structuring Alternative Investments in Luxembourg
Programme outline
This programme comprises a series of 4-modules which will provide participants with a 360' degree overview of the new tax environment in which Alternative Investments have to navigate.
The modules cover (i) the new tax rules that have been implemented in accordance with the Anti-Tax Avoidance Directives (ATAD 1 & 2), (iii) substance requirements in the post-BEPS world, (iii) transfer pricing aspects and (iv) reporting obligations under the mandatory disclosure regime (DAC 6):
Module 1- 17/09/24 from 14.00- 17.00: Structuring alternative investments in the post-BEPS era
Module 2 - 24/09/24 from 14.00-17.00: Substance requirements
Module 3 - 08/10/24 from 14.00-17.00: Transfer pricing and related documentation
Module 4- 17/10/24 from 14.00-17.00: The mandatory disclosure regime (DAC 6)
If you are interested to attend all 4 modules, you can register on this page at an advantageous rate. Should you only wish to attend some of the modules, please click on the above links where you can register separately.
Target audience
The training will be targeted to Non-Executive Directors and people that would like to gain a clear understanding of the new hybrid mismatch rules and where these might be problematic in practice.
Speakers
Agenda and schedule
1:45 PM
Module 1 - Tax structuring aspects
Registration & welcome coffee
2:00 PM
Welcome and introduction
2:15 PM
Presentation - Implementing alternative investments in the post-BEPS era
- Typical investment structure
- Interest limitation rules
- Hybrid mismatch rules
-
Reverse hybrid mismatch rule
3:30 PM
Coffee break
3:45 PM
- General anti-abuse rule
- Considering the tax treatment in the investment jurisdiction
- Cash reparation
5:00 PM
Closing
1:45 PM
Module 2 - Substance requirements
Registration & welcome coffee
2:00 PM
Welcome and introduction
2:15 PM
The importance of Substance in the post-BEPS era
Overview of the notion of substance
Analysing the importance of substance in international tax
- Requirements from a Luxembourg tax and regulatory perspective
- Requirements from a foreign tax perspective
- Requirements from a tax treaty perspective
- Requirements from a transfer pricing perspective
- Reputational risk s
3:30 PM
Coffee break
3:45 PM
Considering typical substance models
- Master holding company
- Management or service company
- Outsourcing model
Considerations regarding ATAD 3 (shell entities)
5:00 PM
Closing
1:45 PM
Module 3 - Transfer pricing and related documentation
Registration & welcome coffee
2:00 PM
Welcome and introduction
2:15 PM
Snapshot of the Luxembourg transfer pricing landscape
The arm's length principle
Tax risks in relation to transfer pricing
Typical controlled transactions in Luxembourg
- Intra-group loans and other debt instruments
- Financing activities
- Intra-group services
- Fund management services
The new reporting obligations on intra-group transactions
3:30 PM
Coffee break
3:45 PM
The transfer pricing regime applicable to Luxembourg finance companies
Transfer pricing documentation
- Documentation requirements under Luxembourg tax law
- Management of tax risks in the absence of tax rulings
- Guidance provided under the OECD Transfer Pricing Guidelines
Best practice recommendations
5:00 PM
Closing
1:30 PM
Module 4 - The Mandatory Disclosure Regime (DAC 6)
Registration & welcome coffee
2:00 PM
Welcome and introduction
2:15 PM
The Mandatory Disclosure Regime (DAC 6)
- Purpose and design principles of the mandatory disclosure regime
- Key features of the mandatory disclosure regime
- Analysing the hallmarks that may trigger reporting obligations
- The importance of the main benefit test (“MBT”) when determining reportable cross-border arrangements
- How to manage compliance with the MDR in practice (intermediaries vs. taxpayers)
- Developing a pragmatic approach
3:30 PM
Coffee break
3:45 PM
Practical case studies
5:00 PM
Closing
8:45 AM
Registration & welcome coffee
9:00 AM
Welcome and introduction
9:30 AM
Luxembourgish company law - basics for Directors
Main commercial company types, Shareholder meetings , Board meetings and their functioning, Delegation, Liquidation
10:45 AM
Coffee break
11:00 AM
Directors' duties & liabilities
12:00 PM
Luxembourgish company law (continued)
12:30 PM
Lunch
8:45 AM
Registration & welcome coffee
9:00 AM
Welcome and introduction
9:30 AM
Luxembourgish company law - basics for Directors
Main commercial company types, Shareholder meetings , Board meetings and their functioning, Delegation, Liquidation
10:45 AM
Coffee break
11:00 AM
Directors' duties & liabilities
12:00 PM
Luxembourgish company law (continued)
12:30 PM
Lunch
1:30 PM
Registration & welcome coffee
1:45 PM
Welcome and introduction
9:30 AM
Luxembourgish company law - basics for Directors
Main commercial company types, Shareholder meetings , Board meetings and their functioning, Delegation, Liquidation
10:45 AM
Coffee break
11:00 AM
Directors' duties & liabilities
12:00 PM
Luxembourgish company law (continued)
12:30 PM
Lunch
1:30 PM
Registration & welcome coffee
1:45 PM
Welcome and introduction
9:30 AM
Luxembourgish company law - basics for Directors
Main commercial company types, Shareholder meetings , Board meetings and their functioning, Delegation, Liquidation
10:45 AM
Coffee break
11:00 AM
Directors' duties & liabilities
12:00 PM
Luxembourgish company law (continued)
12:30 PM
Lunch
Start with the customer – find out what they want and give it to them.
Venue
Chambre de Commerce Luxembourg
7 Rue Alcide de Gasperi
1615 Luxembourg - Luxembourg
Contact the organiser
Institut Luxembourgeois des Administrateurs
events@ila.lu
| +352 26 49 58 5963