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 last of seven seminars on alternative investments, focusing on the important concepts of hidden dividend distributions and hidden capital contributions.
We'll answer:
- What are the characteristics and tax consequences of these concepts?
- What is the relationship between these concepts and Article 56 of the LITL?
- How should triangular cases – involving companies in a chain or sister companies – be treated?
All these questions will be analysed during this seminar with practical case studies. Walk away with the know-how to identify and manage hidden distributions and contributions.
Agenda
· Introduction
· Hidden dividend distributions (HDD)
- Characteristics of HDD
- Tax treatment of HDD
- Cross-border situations
- Practical case studies
· Hidden capital contributions (HCC)
o Characteristics of HCC
o Tax treatment of HCC
o Cross-border situations
o Practical case studies
· Article 56 of the LITL
o Scope of Article 56 of the LITL
o Tax adjustments under Article 56 of the LITL
o Hierarchie of norms
- Triangular cases
- Transactions in a chain of companies
- Transactions involving sister companies
- Transactions involving related parties of individual shareholders
- Cross-border situations
- Practical case studies
- Summary
Dates 16 October 2026
Time 1:30 pm – 2 pm Registration
2 pm – 5:30 pm Presentation (15 min break)
Expected duration : 3h30
Our speaker
Oliver R. Hoor
(Tax Partner, ATOZ) will lead the seven seminars. Participants can book the full course or choose individual modules.
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]
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