The hybrid mismatch rules and the reverse hybrid mismatch rule – cutting through complexity
PRESENTATION
PROGRAM
Introduction
Hybrid mismatch rules
Mismatch outcomes
Relevant hybrid mismatch rule in the context of Alternative Investments
Scope of the hybrid mismatch rules
Related party test
Carve-out for minority investors in a fund context
Limits of the hybrid mismatch rules
Neutralisation of mismatch outcomes
Burden of proof
Case studies
Reverse hybrid mismatch rule
Scope of the reverse hybrid mismatch rule
Related party test
Carve-out for minority investors in a fund context
Exclusion of investors on grounds of their tax status
Tax treatment of reverse hybrid entities
Burden of proof
Case studies
Conclusion
SPEAKERS
OLIVER R. HOOR
Tax Partner and Head of Transfer Pricing, ATOZ Tax Advisers
Oliver is a Partner in the International & Corporate Tax department at ATOZ.
A tax professional since 2003, Oliver 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. He also holds the titles of Head of Transfer Pricing and of the German Desk.
Oliver is the author of more than 250 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/ATAD 2), reporting obligations of tax intermediaries (DAC6), 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 also a regular speaker at conferences as well as being a lecturer with Legitech and ILA.
Oliver is qualified as a Chartered Accountant in Luxembourg ("Expert-Comptable") and is 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.
He speaks German, English and French.
FRAIS D'INSCRIPTION
La société Legitech a obtenu l'agrément du Barreau de Luxembourg
DATA PRIVACY
Les coordonnées des participants seront communiquées à Atoz Tax Advisers à des fins d'organisation.
CONTACT
Mme Carole Verdicq
Tél: 0032 10 42 02 96
Email: [email protected]