The importance of substance
This course is part of a 4-Module training program, 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 program at an advantageous rate please follow this link: Alternative investments in the post-BEPS era - Training program
This training will be of significant importance for independent directors that need to have a clear understanding of substance requirements in international taxation. While substance has always been important for Luxembourg companies that frequently operate in a cross-border context, the OECD Base Erosion and Profit Shifting (“BEPS”) Project only elevated their importance in an international tax environment that is characterized by total transparency. The more recent initiative of the EU Commission in regard to shell entities is evidence that the topic of substance will remain high on the agenda.
The main features of the program 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
The new initiative of the EU Commission in regard to shell entities
Organisation of substance: Analysing how substance might be organised in practice (looking at different substance models)
Benefits of the program
The training will be very practical and provide participants with a clear view on the complicated topic of substance.
The training will be targeted to directors and people that would like to gain a clear understanding of the importance of substance in international tax.