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BEGIN:VEVENT
UID:20261016T182454Z - 27226@eupv478
DTSTART;TZID=Europe/Luxembourg:20241023T140000
DTEND;TZID=Europe/Luxembourg:20241023T160000
CREATED:20261016T182454Z
DESCRIPTION:<a href="https://www.legitech.lu/event/financing-holding-of-sha
 res-and-deduction-of-input-vat-an-infernal-triangle-863/register">Financin
 g\, holding of shares and deduction of input VAT: an infernal triangle?</a
 >\nPresentation: The right to deduct input VAT for holding and financing c
 ompanies is an important source of VAT audits and disputes before the Luxe
 mbourg Courts and Tribunals – and has been for several years. Although t
 he case law of the Court of Justice of the European Union is quite clear\,
  its application by the taxpayers\, by the AEDT and the local courts\, som
 etimes gives rise to some difficulties if not unpleasant surprises. Howeve
 r\, a consistent and documented approach should enable VAT taxable persons
  to make full use of the basic right to deduct input VAT when the conditio
 ns are met. In this session\, we will discuss:­ the basic rules of the ri
 ght to deduct for holding companies and financing activities as they deriv
 e from European law and the case law of the Court of Justice\;­ the lesso
 ns of local case law\, and its evolution as the AEDT's positions on these 
 issues change\;­ the practice of AEDT and its developments\, in particula
 r the so-called "1:1" principle\, circulars 765 and 765-1\;­ the structur
 es at risk\, "red flags" and shortcomings generally observed\; ­ best pra
 ctices\, both in the determination of the right to deduct and in the docum
 entation of taxable persons' transactions. This conference will be of part
 icular interest to all tax professionals working on Luxembourg tax matters
 \, whether as in house or as service providers. Speaker for this session: 
 Olivier Coulon : Counsel at SIMON Law Olivier Coulon specialises in VAT la
 w and advises both international clients and Luxembourg operators. Through
  his background\, Olivier has expertise in VAT for multinational groups as
  well as in the structuring of private equity transactions and regulated a
 nd non-regulated Luxembourg alternative investment funds. He also assists 
 his clients in the field of tax litigation\, both in the pre-litigation ph
 ase and before the Luxembourg courts. Olivier is a member of the [...]
DTSTAMP:20261016T182454Z
LOCATION:Sofitel Luxembourg Europe\, 6 rue du Fort Niedergrünewald\, Luxem
 bourg  2226\, Luxembourg
SUMMARY:Financing\, holding of shares and deduction of input VAT: an infern
 al triangle?
X-ALT-DESC;FMTTYPE=text/html:<a href="https://www.legitech.lu/event/financi
 ng-holding-of-shares-and-deduction-of-input-vat-an-infernal-triangle-863/r
 egister">Financing\, holding of shares and deduction of input VAT: an infe
 rnal triangle?</a>\nPresentation: The right to deduct input VAT for holdin
 g and financing companies is an important source of VAT audits and dispute
 s before the Luxembourg Courts and Tribunals – and has been for several 
 years. Although the case law of the Court of Justice of the European Union
  is quite clear\, its application by the taxpayers\, by the AEDT and the l
 ocal courts\, sometimes gives rise to some difficulties if not unpleasant 
 surprises. However\, a consistent and documented approach should enable VA
 T taxable persons to make full use of the basic right to deduct input VAT 
 when the conditions are met. In this session\, we will discuss:­ the basi
 c rules of the right to deduct for holding companies and financing activit
 ies as they derive from European law and the case law of the Court of Just
 ice\;­ the lessons of local case law\, and its evolution as the AEDT's po
 sitions on these issues change\;­ the practice of AEDT and its developmen
 ts\, in particular the so-called "1:1" principle\, circulars 765 and 765-1
 \;­ the structures at risk\, "red flags" and shortcomings generally obser
 ved\; ­ best practices\, both in the determination of the right to deduct
  and in the documentation of taxable persons' transactions. This conferenc
 e will be of particular interest to all tax professionals working on Luxem
 bourg tax matters\, whether as in house or as service providers. Speaker f
 or this session: Olivier Coulon : Counsel at SIMON Law Olivier Coulon spec
 ialises in VAT law and advises both international clients and Luxembourg o
 perators. Through his background\, Olivier has expertise in VAT for multin
 ational groups as well as in the structuring of private equity transaction
 s and regulated and non-regulated Luxembourg alternative investment funds.
  He also assists his clients in the field of tax litigation\, both in the 
 pre-litigation phase and before the Luxembourg courts. Olivier is a member
  of the [...]
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