BEGIN:VCALENDAR VERSION:2.0 PRODID:-//PYVOBJECT//NONSGML Version 1//EN BEGIN:VTIMEZONE TZID:Europe/Brussels 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:20260618T094000Z - 78881@eupv478 DTSTART;TZID=Europe/Brussels:20230316T140000 DTEND;TZID=Europe/Brussels:20230316T170000 CREATED:20260618T094000Z DESCRIPTION:The hybrid mismatch rules and the reverse hybrid mismatch rule – c utting through complexity\nPRESENTATION Hybrid mismatches typically or iginate from a different tax treatment of an entity\, a permanent establis hment or a financial instrument under the laws of two or more jurisdiction s and may result in deduction without inclusion or double deduction outcom es. In general\, the hybrid mismatch rules target hybrid mismatches betwee n associated enterprises\, structured arrangements between third parties\, imported hybrid mismatches and tax residency mismatches. At the same time \, the hybrid mismatch rules should not create economic double taxation. T his is ensured through a number of carve-outs and limitations that dischar ge the application of the hybrid mismatch rules (for example\, timing diff erences\, inclusion of the payment at the level of any payee\, tax exempt status of the investor\, transfer pricing adjustments). This workshop aims at providing participants with a clear overview of the hybrid mismatch ru les and the reverse hybrid mismatch rule (the scope of which has been clar ified recently)\, analyses how these rules may impact Alternative Investme nts in Luxembourg and considers opportunities to manage adverse tax conseq uences in practice. PROGRAM Introduction Hybrid mismatch rules Mismatch ou tcomes Relevant hybrid mismatch rule in the context of Alternative Investm ents Scope of the hybrid mismatch rules Related party test Carve-out for m inority investors in a fund context Limits of the hybrid mismatch rules Ne utralisation of mismatch outcomes Burden of proof Case studies Reverse hyb rid mismatch rule Scope of the reverse hybrid mismatch rule Related party test Carve-out for minority investors in a fund context Exclusion of inves tors on grounds of their tax status Tax treatment of reverse hybrid entiti es Burden of proof Case studies ConclusionSPEAKERS OLIVER R. HOOR Tax Part ner and Head of Transfer Pricing\, ATOZ Tax Advisers Oliver is a Partner i n the [...] DTSTAMP:20260618T094000Z LOCATION:ATOZ Tax Advisers\, Aerogolf Center\, 1B rue Heienhaff\, Senninger berg 1736\, Luxembourg SUMMARY:The hybrid mismatch rules and the reverse hybrid mismatch rule – cutting through complexity X-ALT-DESC;FMTTYPE=text/html:The hybrid mismatch rules and the reverse hybrid mi smatch rule – cutting through complexity\nPRESENTATION Hybrid mismat ches typically originate from a different tax treatment of an entity\, a p ermanent establishment or a financial instrument under the laws of two or more jurisdictions and may result in deduction without inclusion or double deduction outcomes. In general\, the hybrid mismatch rules target hybrid mismatches between associated enterprises\, structured arrangements betwee n third parties\, imported hybrid mismatches and tax residency mismatches. At the same time\, the hybrid mismatch rules should not create economic d ouble taxation. This is ensured through a number of carve-outs and limitat ions that discharge the application of the hybrid mismatch rules (for exam ple\, timing differences\, inclusion of the payment at the level of any pa yee\, tax exempt status of the investor\, transfer pricing adjustments). T his workshop aims at providing participants with a clear overview of the h ybrid mismatch rules and the reverse hybrid mismatch rule (the scope of wh ich has been clarified recently)\, analyses how these rules may impact Alt ernative Investments in Luxembourg and considers opportunities to manage a dverse tax consequences in practice. PROGRAM Introduction Hybrid mismatch rules Mismatch outcomes Relevant hybrid mismatch rule in the context of Al ternative Investments Scope of the hybrid mismatch rules Related party tes t Carve-out for minority investors in a fund context Limits of the hybrid mismatch rules Neutralisation of mismatch outcomes Burden of proof Case st udies Reverse hybrid mismatch rule Scope of the reverse hybrid mismatch ru le Related party test Carve-out for minority investors in a fund context E xclusion of investors on grounds of their tax status Tax treatment of reve rse hybrid entities Burden of proof Case studies ConclusionSPEAKERS OLIVER R. HOOR Tax Partner and Head of Transfer Pricing\, ATOZ Tax Advisers Oliv er is a Partner in the [...] END:VEVENT END:VCALENDAR