BEGIN:VCALENDAR VERSION:2.0 PRODID:-//PYVOBJECT//NONSGML Version 1//EN BEGIN:VTIMEZONE TZID:Europe/Luxembourg BEGIN:STANDARD DTSTART:20001029T030000 RRULE:FREQ=YEARLY;BYDAY=-1SU;BYMONTH=10 TZNAME:CET TZOFFSETFROM:+0200 TZOFFSETTO:+0100 END:STANDARD BEGIN:DAYLIGHT DTSTART:20000326T020000 RRULE:FREQ=YEARLY;BYDAY=-1SU;BYMONTH=3 TZNAME:CEST TZOFFSETFROM:+0100 TZOFFSETTO:+0200 END:DAYLIGHT END:VTIMEZONE BEGIN:VEVENT UID:20260610T042138Z - 12223@eupv478 DTSTART;TZID=Europe/Luxembourg:20260924T140000 DTEND;TZID=Europe/Luxembourg:20260924T173000 CREATED:20260610T042138Z DESCRIPTION:Module 3 : Su bstance requirements - Alternative Investments in Luxembourg\nDescript ion Luxembourg is the location of choice for the implementation of alterna tive investments (private equity\, private debt\, real estate\, infrastruc ture\, ...). As the largest fund center in Europe (and the second in the w orld)\, Luxembourg holds an impressive 56% of the global market for cross- border investment funds. This is the third of seven seminars\, focusing on substance requirements – a long-standing issue for Luxembourg companies active in cross-border business. Following the OECD's BEPS project\, the importance of substance has only increased\, and it is now frequently scru tinised by foreign tax authorities. But what exactly is substance in inter national taxation? What is the importance of Luxembourg (professional) res ident directors and good corporate governance? How can an appropriate leve l of substance be determined and managed in practice? And what are the tac tics of foreign tax authorities when challenging the substance of Luxembou rg companies? All these questions will be answered in this presentation. Y ou'll walk away with practical guidance on documenting\, maintaining\, and defending substance. Agenda The notion of substance Analysing the importa nce of substance in international tax § Requirements from a Luxembourg ta x and regulatory perspective § Requirements from a foreign tax perspectiv e § Requirements from a tax treaty perspective § Requirements from a tra nsfer pricing perspective § Reputational risks Limits of anti-abuse legis lation in an EU context Considering typical substance models § Master hol ding company § Management or service company § Outsourcing model Tactics of foreign tax authorities when challenging substance § Challenging tax residency § Construing a management permanent establishment § Construing an operational permanent establishment § Challenging beneficial ownershi p § Challenging transfer pricing Considerations regarding [...] DTSTAMP:20260610T042138Z LOCATION:Sofitel Luxembourg Europe\, 6 rue du Fort Niedergrünewald\, Luxem bourg 2226\, Luxembourg SUMMARY:Module 3 : Substance requirements - Alternative Investments in Luxe mbourg X-ALT-DESC;FMTTYPE=text/html:Module 3 : Substance requirements - Alternative Investments in Luxembo urg\nDescription Luxembourg is the location of choice for the implemen tation of alternative investments (private equity\, private debt\, real es tate\, infrastructure\, ...). As the largest fund center in Europe (and th e second in the world)\, Luxembourg holds an impressive 56% of the global market for cross-border investment funds. This is the third of seven semin ars\, focusing on substance requirements – a long-standing issue for Lux embourg companies active in cross-border business. Following the OECD's BE PS project\, the importance of substance has only increased\, and it is no w frequently scrutinised by foreign tax authorities. But what exactly is s ubstance in international taxation? What is the importance of Luxembourg ( professional) resident directors and good corporate governance? How can an appropriate level of substance be determined and managed in practice? And what are the tactics of foreign tax authorities when challenging the subs tance of Luxembourg companies? All these questions will be answered in thi s presentation. You'll walk away with practical guidance on documenting\, maintaining\, and defending substance. Agenda The notion of substance Anal ysing the importance of substance in international tax § Requirements fro m a Luxembourg tax and regulatory perspective § Requirements from a forei gn tax perspective § Requirements from a tax treaty perspective § Requir ements from a transfer pricing perspective § Reputational risks Limits of anti-abuse legislation in an EU context Considering typical substance mod els § Master holding company § Management or service company § Outsourc ing model Tactics of foreign tax authorities when challenging substance § Challenging tax residency § Construing a management permanent establishm ent § Construing an operational permanent establishment § Challenging be neficial ownership § Challenging transfer pricing Considerations regardin g [...] END:VEVENT END:VCALENDAR