Description

Luxembourg is the leading hub for alternative investments – private equity, private debt, real estate, infrastructure, and more. As Europe's largest fund center (and the world's second largest), it holds an impressive 56% of the global market for cross-border investment funds.

This is the sixth of seven seminars on alternative investments, focusing on tax treaties.

Luxembourg has an extensive tax treaty network, with more than 90 treaties in force. But how do these treaties actually work? In this seminar, we'll answer:

• What is the mechanism of tax treaties drafted along the lines of the OECD Model Tax Convention?
• How do tax treaties allocate taxing rights to the contracting states?
• How is double taxation eliminated?
• What is the relationship between tax treaties and domestic tax law?

All these questions will be answered in this seminar.

Agenda 

·        Introduction

·        Reasons for double taxation

·        Structure, scope and mechanics of tax treaties

         o   Structure of the OECD Model

         o   Scope of tax treaties  

         o   Mechanics of the OECD Model

         o   Special provisions (Art. 24 – 29 of the OECD Model)

         o   Final provisions (Art. 30 – 31 of the OECD Model)

• Taxation of income and capital          
• • Income from immovable property (Art. 6 of the OECD Model)
  • Business profits (Art. 7 of the OECD Model)
  • Dividends (Art. 10 of the OECD Model)
  • Interest (Art. 11 of the OECD Model)
  • Royalties (Art. 12 of the OECD Model)
  • Capital gains (Art. 13 of the OECD Model)
• Methods for the elimination of double taxation
• • The exemption method (Art. 23 A of the OECD Model)
  • The credit method (Art. 23 B of the OECD Model)
• Practical case studies

 Dates    13 October 2026

 Time     1:30 pm – 2 pm          Registration

                          2 pm – 5:30 pm               Presentation (15 min break)

                          Expected duration :       3h30

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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