Description
Luxembourg is the location of choice for the implementation of alternative investments (private equity, private debt, real estate, infrastructure, ...). As the largest fund center in Europe (and the second in the world), Luxembourg holds an impressive 56% of the global market for cross-border investment funds.
This is the fourth in a series of seven seminars on alternative investments, focusing on transfer pricing and related documentation – an area of growing scrutiny following the OECD's BEPS project.
Key questions we'll answer:
- What are typical intra-group transactions in the alternative investment context?
- Which transfer pricing rules apply in Luxembourg?
- What transfer pricing methods should typically be applied?
- How can transfer pricing risks be effectively mitigated?
- What does best practice look like for transfer pricing documentation?
Walk away with
practical strategies to manage risk and defend your documentation.
Agenda
Snapshot of the Luxembourg transfer pricing landscape
The arm's length principle
Tax risks in relation to transfer pricing
Typical controlled transactions in Luxembourg
§ Intra-group loans and other debt instruments
§ Financing activities
§ Intra-group services
§ Fund management services
The new reporting obligations on intra-group transactions
The transfer pricing regime applicable to Luxembourg finance companies
Transfer pricing documentation
§ Documentation requirements under Luxembourg tax law
§ Management of tax risks in the absence of tax rulings
§ Guidance provided under the OECD Transfer Pricing Guidelines
Best practice recommendations
Dates 29 September 2026
Time 1:30 pm – 2 pm Registration
2 pm – 5 pm Presentation (15 min break)
Expected duration : 3h
Our speaker
Oliver R. Hoor
(Tax Partner, ATOZ) will lead the seven seminars. Participants can book the full course or choose individual modules.
About the Presenter
Oliver
R. Hoor
Oliver R. Hoor is a Partner in the International and Corporate Tax department of ATOZ. He is the Head of Transfer Pricing.
A tax professional since 2003, Oliver has experience in Luxembourg and international taxation with a focus on Alternative Investments (private equity, real estate, infrastructure, private debt), mergers & acquisitions and multinational groups. Oliver advises clients on all direct tax aspects regarding deal structuring, maintenance, reorganisations and exit planning.
Oliver is a member of the tax working groups of the Luxembourg Private Equity Association (LPEA) and the Association of the Luxembourg Fund Industry (ALFI). He is further a founding member of the Luxembourg Transfer Pricing Association (LTPA), a member of the tax committee of the Luxembourg Alternative Administrators Association (L3A), and a member of the International Fiscal Association (IFA).
Oliver is the author of more than 300 articles and books on Luxembourg and international taxation including Transfer Pricing and related documentation requirements, the OECD Base Erosion and Profit Shifting (“BEPS”) Project and the EU Anti-Tax Avoidance Directives (ATAD 1 & 2), reporting obligations of tax intermediaries (DAC6), current initiatives of the EU Commission in the field of direct taxation (ATAD 3, BEFIT, DEBRA, SAFE, DAC8, …), the OECD Model Tax Convention and Tax Treaties, EU Law and the State Aid investigations of the EU Commission (see www.atoz.lu/media-room). He is a regular speaker at conferences and a lecturer with Legitech and the Luxembourg Institute of Governance (ILA).
Oliver is qualified as a Chartered Accountant in Luxembourg (“Expert-Comptable”) as well as a certified German tax adviser (“Steuerberater”). He holds a post-graduate degree in Luxembourg Tax and a degree in Business Administration with a major in Tax from the University of Applied Sciences of Trier (Germany).
Alternative Investments in Luxembourg
Module 1: The Luxembourg toolbox : Find out more here
Module 2: Structuring Alternative Investments : Find out more here
Module 3: Substance requirements : Find out more here
Module 4: Transfer pricing and related documentation requirements : Find out more here
Module 5: The mandatory disclosure regime (DAC 6) : Find out more here
Module 6: Tax treaties : Find out more here
Module 7: Hidden dividend distributions and hidden capital contributions : Find out more here
Registration :
Registration for a single module : €335 incl. VAT
Registration for the full programme : €1450 incl. VAT
- 15% discount for 2 participants from the same organisation (please contact the Training Department at [email protected])
- 20% discount for 3 or more participants from the same organisation (please contact the Training Department at [email protected])
Accréditation :
Legitech has obtained accreditation from the Luxembourg Bar.
Co-funding :
Our training courses are eligible for co-funding.
Legitech is authorised to operate as a continuing professional training provider.
Authorisation No. 10001428/4.
Contact :
For any questions regarding this training programme, please contact Florence Guy at: [email protected]
Click here for more information about our "Vouchers".
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