Description

Luxembourg is the location of choice for the implementation of alternative investments (private equity, private debt, real estate, infrastructure, ...). As the largest fund center in Europe (and the second in the world), Luxembourg holds an impressive 56% of the global market for cross-border investment funds.

This is the fourth in a series of seven seminars on alternative investments, focusing on transfer pricing and related documentation – an area of growing scrutiny following the OECD's BEPS project.

Key questions we'll answer:

• What are typical intra-group transactions in the alternative investment context?
• Which transfer pricing rules apply in Luxembourg?
• What transfer pricing methods should typically be applied?
• How can transfer pricing risks be effectively mitigated?
• What does best practice look like for transfer pricing documentation?

Walk away with practical strategies to manage risk and defend your documentation.

Agenda 

Snapshot of the Luxembourg transfer pricing landscape

The arm's length principle

Tax risks in relation to transfer pricing

Typical controlled transactions in Luxembourg

     §  Intra-group loans and other debt instruments

     §  Financing activities 

     §  Intra-group services

     §  Fund management services

The new reporting obligations on intra-group transactions

The transfer pricing regime applicable to Luxembourg finance companies

Transfer pricing documentation

     §  Documentation requirements under Luxembourg tax law

     §  Management of tax risks in the absence of tax rulings

     §  Guidance provided under the OECD Transfer Pricing Guidelines

Best practice recommendations

 Dates    29 September 2026

 Time     1:30 pm – 2 pm          Registration

                          2 pm – 5 pm                     Presentation (15 min break)

                          Expected duration :       3h

About the Presenter

                  Oliver R. Hoor

Oliver R. Hoor is a Partner in the International and Corporate Tax department of ATOZ. He is the Head of Transfer Pricing.

A tax professional since 2003, Oliver has experience in Luxembourg and international taxation with a focus on Alternative Investments (private equity, real estate, infrastructure, private debt), mergers & acquisitions and multinational groups. Oliver advises clients on all direct tax aspects regarding deal structuring, maintenance, reorganisations and exit planning.

Oliver is a member of the tax working groups of the Luxembourg Private Equity Association (LPEA) and the Association of the Luxembourg Fund Industry (ALFI). He is further a founding member of the Luxembourg Transfer Pricing Association (LTPA), a member of the tax committee of the Luxembourg Alternative Administrators Association (L3A), and a member of the International Fiscal Association (IFA).

Oliver is the author of more than 300 articles and books on Luxembourg and international taxation including Transfer Pricing and related documentation requirements, the OECD Base Erosion and Profit Shifting (“BEPS”) Project and the EU Anti-Tax Avoidance Directives (ATAD 1 & 2), reporting obligations of tax intermediaries (DAC6), current initiatives of the EU Commission in the field of direct taxation (ATAD 3, BEFIT, DEBRA, SAFE, DAC8, …), the OECD Model Tax Convention and Tax Treaties, EU Law and the State Aid investigations of the EU Commission (see www.atoz.lu/media-room). He is a regular speaker at conferences and a lecturer with Legitech and the Luxembourg Institute of Governance (ILA).

Oliver is qualified as a Chartered Accountant in Luxembourg (“Expert-Comptable”) as well as a certified German tax adviser (“Steuerberater”). He holds a post-graduate degree in Luxembourg Tax and a degree in Business Administration with a major in Tax from the University of Applied Sciences of Trier (Germany).

Alternative Investments in Luxembourg

Module 1: The Luxembourg toolbox : Find out more here 

Module 2: Structuring Alternative Investments : Find out more here 

Module 3: Substance requirements : Find out more here 

Module 4: Transfer pricing and related documentation requirements : Find out more here 

Module 5: The mandatory disclosure regime (DAC 6) : Find out more here 

Module 6: Tax treaties : Find out more here 

Module 7: Hidden dividend distributions and hidden capital contributions : Find out more here 

Registration  :

Registration for a single module  : €335   incl. VAT

Registration for the full programme  : €1450   incl. VAT

• 15% discount for 2 participants from the same organisation (please contact the Training Department at [email protected])
• 20% discount for 3 or more participants from the same organisation (please contact the Training Department at [email protected])

Accreditation :

Legitech has obtained accreditation from the Luxembourg Bar.

Co-funding :

Our training courses are eligible for co-funding.

Legitech is authorised to operate as a continuing professional training provider.

Authorisation No. 10001428/4.

Contact :

For any questions regarding this training programme, please contact Florence Guy at: [email protected]

Click here  for more information about our "Vouchers".

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