Substance requirements (Module 2)

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Course outline

This is the 2nd module of the programme that will provide a clear and concise understanding of the concept of substance in international taxation, consider the reasons for substance requirements and their limitations, and analyse how substance can be effectively organised in practice.   

As such, participants will learn about the issues that need to be considered when implementing and maintaining an appropriate substance in relation to cross-border investments.

This training will be of interest for Non-Executive Directors that need to have a clear understanding of the tax environment applicable to Alternative Investments such as Private Equity, Real Estate and Infrastructure investments. 

This course is part of a 4-Module training programme, providing participants with a 360' degree overview of the new tax environment in which Alternative Investments have to navigate. Should you wish to register to the full programme at an advantageous rate, please follow this link:  Structuring Alternative Investments in Luxembourg - Training programme

Course highlights 

The main features of the course are:

  • Substance requirements: Analysing the reasons of substance requirements from a Luxembourg perspective, a foreign tax perspective, a tax treaty perspective, a transfer pricing perspective and a reputational risk perspective
  • Limits of anti-abuse legislation (substance requirements) in an EU context
  • Considerations regarding the initiative of the EU Commission regarding shell entities (also referred to as “ATAD 3”)
  • Organisation of substance: Analysing how substance might be organised in practice (looking at different substance models) 

Benefits of the course

The training will be very practical and provide participants with a clear view on the intricate topic of substance.

Target audience

The training is aimed at  Non-Executive Directors and those who wish to gain a clear understanding of how alternative investments are commonly organised (with a focus on their tax treatment).

Date & Time

24/09/2024 - 14:00


Chambre de Commerce du Luxembourg

CPD hours

3.0 hours

Book your spot

Member fee : 240,00€  (VAT excl.)

Non-member fee: 340,00€  (VAT excl.)

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Oliver R.  HOOR

ATOZ Tax Advisers Luxembourg

Agenda and schedule


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Chambre de Commerce Luxembourg

7 Rue Alcide de Gasperi 

1615 Luxembourg - Luxembourg

Contact the organiser

Institut Luxembourgeois des Administrateurs  | +352 26 49 58 5963