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

À qui s'adresse la formation?

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.

Durée

3,00 heure(s)

Langues(s) de prestation

Prochaine session

Contacter l'organisme

Objectifs

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

Contenu

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