Analysing the impact of the new hybrid mismatch rules (ATAD 2) on Alternative Investments
Fanny is a Director in the International and Corporate Tax department at ATOZ.
A tax professional since 2011, Fanny worked in the accounting sector for 2 years with a Big4 in France before focusing on international tax in Luxembourg. Fanny has experience in relation to the structuring of Alternative Investments via Luxembourg (private equity, real estate, infrastructure, etc.) as well as mergers & acquisitions (multinational groups). She also provides tax advisory services to clients in the Luxembourg banking area with a particular focus on the treatment of transactions under Luxembourg GAAP and IFRS.
Fanny is a member of the Core Transfer Pricing Team of ATOZ that develops new transfer pricing services and deals with complex, non-standard transfer pricing engagements. She further advises on the new reporting obligations of tax intermediaries under the mandatory disclosure regime (DAC 6).
Fanny holds a post-graduate degree in Luxembourg Tax. She holds a Master’s degree in Accounting (French GAAP, IFRS), Finance and Management as well as a Master’s degree in Business and Tax Law from the University of Strasbourg (France).
HOOR Oliver R.
Oliver is a Partner in the International and Corporate Tax Department of ATOZ.
A tax professional since 2003, Oliver has experience in Luxembourg and international taxation with a focus on alternative Investments (private equity, real estate, sovereign wealth funds, hedge funds), mergers & acquisitions and multinational groups. Oliver advises clients on all direct tax aspects regarding deal structuring, maintenance, reorganisations and exit planning.
He is Head of Transfer Pricing and the German Desk. Oliver is further a member of the tax working groups of the Association of the Luxembourg Fund Industry (ALFI) and the Luxembourg Private Equity Association (LPEA).
Oliver is the author of more than 250 articles and books on Luxembourg and international taxation including Transfer Pricing and related documentation requirements, the OECD Base Erosion and Profit Shifting (“BEPS”) Project and the EU Anti-Tax Avoidance Directives (ATAD 1 & 2), reporting obligations of tax intermediaries (DAC 6), the OECD Model Tax Convention and Tax Treaties, EU Law and the State Aid investigations of the EU Commission. He is also a regular speaker at conferences and a lecturer with House of Training and Legitech.
Oliver is qualified as a Chartered Accountant in Luxembourg (“Expert-Comptable”) as well as a certified German tax adviser (“Steuerberater”). He holds a post-graduate degree in Luxembourg Tax and a degree in Business Administration with a major in Tax from the University of Applied Sciences of Trier (Germany).