Structuring Alternative Investments (Private Equity, Real Estate,…) in the post-BEPS era via Luxembourg

Upon successful completion of this course, the student will:

• have an understanding of how crossborder private equity and real estate investments are structured via Luxembourg
• have an overview of the BEPS recommandations, the European Anti-Avoidance Directive and the Multilateral instrument regarding tax treaties impacting Alternative Investment structures
• understand the importance of substance and arm’s length conditions when structuring investments
• have a clear view on how the changes of the international tax landscape will impact Alternative Investments

• Overview of Alternative Investments structures via Luxembourg
• The OECD BEPS Project and related actions at EU level
• BEPS measures and their impact on Alternative Investment structures
• Determining and organizing the right level of substance
• Optimizing set-ups in the new international tax environment
• Structuring aspects
• The importance of arm’s length conditions and transfer pricing documentation

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

The lecturer is an International Tax Partner with a large tax advisory firm in Luxembourg where he is also heading the Transfer Pricing practice. A tax professional since 2003, he 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. He advises clients on all direct tax aspects regarding deal structuring, maintenance, reorganisations and exit planning.