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BEGIN:VEVENT
UID:20260618T093005Z - 5373@eupv478
DTSTART;TZID=Europe/Luxembourg:20210512T140000
DTEND;TZID=Europe/Luxembourg:20210512T170000
CREATED:20260618T093005Z
DESCRIPTION:<a href="https://www.legitech.lu/event/substance-requirements-1
 14/register">SUBSTANCE REQUIREMENTS</a>\nPRESENTATION Substance is a key e
 lement in international taxation and is relevant for the application of bo
 th domestic tax law and tax treaties. The notion of substance involves a n
 umber of elements such as (i) infrastructure (equipment\, facilities and e
 mployees\, etc.)\, (ii) corporate governance (directorship\, involvement o
 f Luxembourg directors\, the place where decisions are taken\, etc.)\, (ii
 i) functional and risk profile\, (iv) legal documentation and contractual 
 aspects\, (iv) transfer pricing documentation\, (iv) the actual conduct of
  business activities and (v) business purpose. Substance is crucial for ma
 naging the Luxembourg tax residency of companies and to avoid a situation 
 in which a corporate structure is (partially) disregarded under foreign an
 ti-abuse provisions. The notion of substance also concerns the beneficial 
 ownership concept that is employed under tax treaties and\, in some cases\
 , under domestic tax law with the objective to avoid tax treaty or EU dire
 ctive shopping. Appropriate substance is further relevant in order to avoi
 d the application of the PPT in tax treaties. When Luxembourg companies op
 erate in foreign jurisdictions\, it is crucial to avoid the constitution o
 f unintentional permanent establishments that could otherwise give rise to
  controversy and significant tax costs in the respective host states. In p
 ractice\, there are different ways to organize the substance of a Luxembou
 rg company ranging from companies with significant internal resources that
  manage most of the tasks internally to companies that rely\, for cost-eff
 iciency purposes\, on an outsourcing model where certain functions are out
 sourced to qualified service providers (or other group companies and) moni
 tored by the employees or the directors of the company (for example\, acco
 unting and compliance services). In other cases\, asset managers may have 
 significant substance in a [...]
DTSTAMP:20260618T093005Z
SUMMARY:SUBSTANCE REQUIREMENTS
X-ALT-DESC;FMTTYPE=text/html:<a href="https://www.legitech.lu/event/substan
 ce-requirements-114/register">SUBSTANCE REQUIREMENTS</a>\nPRESENTATION Sub
 stance is a key element in international taxation and is relevant for the 
 application of both domestic tax law and tax treaties. The notion of subst
 ance involves a number of elements such as (i) infrastructure (equipment\,
  facilities and employees\, etc.)\, (ii) corporate governance (directorshi
 p\, involvement of Luxembourg directors\, the place where decisions are ta
 ken\, etc.)\, (iii) functional and risk profile\, (iv) legal documentation
  and contractual aspects\, (iv) transfer pricing documentation\, (iv) the 
 actual conduct of business activities and (v) business purpose. Substance 
 is crucial for managing the Luxembourg tax residency of companies and to a
 void a situation in which a corporate structure is (partially) disregarded
  under foreign anti-abuse provisions. The notion of substance also concern
 s the beneficial ownership concept that is employed under tax treaties and
 \, in some cases\, under domestic tax law with the objective to avoid tax 
 treaty or EU directive shopping. Appropriate substance is further relevant
  in order to avoid the application of the PPT in tax treaties. When Luxemb
 ourg companies operate in foreign jurisdictions\, it is crucial to avoid t
 he constitution of unintentional permanent establishments that could other
 wise give rise to controversy and significant tax costs in the respective 
 host states. In practice\, there are different ways to organize the substa
 nce of a Luxembourg company ranging from companies with significant intern
 al resources that manage most of the tasks internally to companies that re
 ly\, for cost-efficiency purposes\, on an outsourcing model where certain 
 functions are outsourced to qualified service providers (or other group co
 mpanies and) monitored by the employees or the directors of the company (f
 or example\, accounting and compliance services). In other cases\, asset m
 anagers may have significant substance in a [...]
END:VEVENT
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