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BEGIN:VEVENT
UID:20260618T105730Z - 34527@eupv478
DTSTART;TZID=Europe/Brussels:20230427T140000
DTEND;TZID=Europe/Brussels:20230427T170000
CREATED:20260618T105730Z
DESCRIPTION:<a href="https://www.legitech.lu/event/structuring-alternative-
 investments-in-the-post-beps-era-module-2-substance-requirements-497/regis
 ter">Structuring alternative investments in the post-BEPS era - module 2: 
 substance requirements</a>\nPRESENTATION Module 2 - 27/04/2023 - 2 to 5 PM
  : substance requirements Substance is a key element in international taxa
 tion and is relevant for the application of both domestic tax law and tax 
 treaties. The notion of substance involves a number of elements such as (i
 ) infrastructure (equipment\, facilities and employees\, etc.)\, (ii) corp
 orate governance (directorship\, involvement of Luxembourg directors\, the
  place where decisions are taken\, etc.)\, (iii) functional and risk profi
 le\, (iv) legal documentation and contractual aspects\, (iv) transfer pric
 ing documentation\, (iv) the actual conduct of business activities and (v)
  business purpose. Substance is crucial for managing the Luxembourg tax re
 sidency of companies and to avoid a situation in which a corporate structu
 re is (partially) disregarded under foreign anti-abuse provisions. The not
 ion of substance also concerns the beneficial ownership concept that is em
 ployed under tax treaties and\, in some cases\, under domestic tax law wit
 h the objective to avoid tax treaty or EU directive shopping. Appropriate 
 substance is further relevant in order to avoid the application of the PPT
  or the beneficial ownership concept in tax treaties. Substance is also in
  the focus of a new EU Directive (ATAD 3\, the so-called Unshell Directive
 ) that may result in reporting obligations and severe tax consequences onc
 e applicable. This workshop will provide a comprehensive overview of the i
 mportance of substance in international taxation. >>> Program Introduction
  The notion of substance Substance requirements in international taxation 
 Substance requirements from a Luxembourg (tax) perspective Managing tax re
 sidency Luxembourg finance companies Requirements from a regulatory perspe
 ctive The proposed regime on shell entities (ATAD 3) Substance requirement
 s from a foreign tax perspective Anti-abuse legislation Considerations reg
 arding [...]
DTSTAMP:20260618T105730Z
LOCATION:ATOZ Tax Advisers\, Aerogolf Center\, 1B rue Heienhaff\, Senninger
 berg  1736\, Luxembourg
SUMMARY:Structuring alternative investments in the post-BEPS era - module 2
 : substance requirements
X-ALT-DESC;FMTTYPE=text/html:<a href="https://www.legitech.lu/event/structu
 ring-alternative-investments-in-the-post-beps-era-module-2-substance-requi
 rements-497/register">Structuring alternative investments in the post-BEPS
  era - module 2: substance requirements</a>\nPRESENTATION Module 2 - 27/04
 /2023 - 2 to 5 PM : substance requirements Substance is a key element in i
 nternational taxation and is relevant for the application of both domestic
  tax law and tax treaties. The notion of substance involves a number of el
 ements such as (i) infrastructure (equipment\, facilities and employees\, 
 etc.)\, (ii) corporate governance (directorship\, involvement of Luxembour
 g directors\, the place where decisions are taken\, etc.)\, (iii) function
 al and risk profile\, (iv) legal documentation and contractual aspects\, (
 iv) transfer pricing documentation\, (iv) the actual conduct of business a
 ctivities and (v) business purpose. Substance is crucial for managing the 
 Luxembourg tax residency of companies and to avoid a situation in which a 
 corporate structure is (partially) disregarded under foreign anti-abuse pr
 ovisions. The notion of substance also concerns the beneficial ownership c
 oncept that is employed under tax treaties and\, in some cases\, under dom
 estic tax law with the objective to avoid tax treaty or EU directive shopp
 ing. Appropriate substance is further relevant in order to avoid the appli
 cation of the PPT or the beneficial ownership concept in tax treaties. Sub
 stance is also in the focus of a new EU Directive (ATAD 3\, the so-called 
 Unshell Directive) that may result in reporting obligations and severe tax
  consequences once applicable. This workshop will provide a comprehensive 
 overview of the importance of substance in international taxation. >>> Pro
 gram Introduction The notion of substance Substance requirements in intern
 ational taxation Substance requirements from a Luxembourg (tax) perspectiv
 e Managing tax residency Luxembourg finance companies Requirements from a 
 regulatory perspective The proposed regime on shell entities (ATAD 3) Subs
 tance requirements from a foreign tax perspective Anti-abuse legislation C
 onsiderations regarding [...]
END:VEVENT
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