Implementation of ATAD 2 into Luxembourg Tax Law - Analysing the Impact on Alternative Investments and Multinationals

Inter-company training

Who is the training for?

Professionals of the financial sector and in-house tax managers that would like to understand the potential impact of the anti-hybrid mismatch rules on Alternative Investments (Real estate, private equity, etc.) and multinational groups that manage their investments via a Luxembourg investment platform.

Duration

3,00 hours(s)

Language(s) of service

EN

Next session

Goals

After the training the participant shall be able to:

  • have a clear understanding of the complex anti-hybrid mismatch rules that will be effective as from 2020
  • understand the impact of the new rules on Alternative Investments structured via Luxembourg
  • understand how Luxembourg investment platforms of multinational groups might be impacted by the new tax measures
  • have a view on structure alignments that might be implemented to manage the tax position in Luxembourg

Contents

  • Overview of the Luxembourg tax reform
  • Types of hybrid mismatch arrangements targeted by the new rules
    • Hybrid mismatches (hybrid financing instruments, hybrid entities, hybrid permanent establishments, etc.)
    • Reverse hybrid mismatches
    • Tax residency mismatches
  • Mechanism of the anti-hybrid mismatch rules
  • Limits of the scope of the new rules
  • Case studies

Certificate, diploma

At the end of the training, the participants will receive a certificate of attendance delivered by the House of Training.

Organization contact details

House of Training

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