Structuring alternative investments in the post-BEPS era - module 1 : structuring of alternative investments

PRESENTATION

Module 1 - 20/04/2023 - 2 to 5 PM : structuring of alternative investments 

Over the last decades, Luxembourg has developed and cemented its position as the location of choice for asset managers implementing Alternative Investments such as private equity, private debt, real estate and infrastructure. 

Although these investment activities where never in the focus of the OECD when developing new tax rules as a result of the organisation’s Base Erosion and Profit Shifting (“BEPS”) Project, the changes that have been/will be implemented in the domestic tax laws of Luxembourg and foreign jurisdictions as well as the changes to bilateral tax treaties and the OECD Transfer Pricing Guidelines will have an impact on the taxation of alternative investments. 

This is the first of four workshops on “Alternative Investments in Luxembourg” which focuses on the impact of different BEPS measures, the European Anti-Tax Avoidance Directives (ATAD/ATAD 2) and related Luxembourg tax law changes on contemporary investment structures. 

 >>> Program 

• Introduction

• Typical investment structures

• The OECD BEPS Project and ATAD/ATAD 2

• Impact of ATAD/ATAD 2 on investments

• • Interest limitation rules

  • Hybrid mismatch rules

  • Reverse hybrid mismatch rule

• Case studies

• Conclusion

OLIVER R. HOOR
Tax Partner and Head of Transfer Pricing, ATOZ Tax Advisers

Oliver is a Partner in the International & Corporate Tax department at ATOZ.

A tax professional since 2003, Oliver has experience in Luxembourg and international taxation with a focus on alternative Investments (private equity, real estate, sovereign wealth funds, hedge funds), mergers & acquisitions and multinational groups. He advises clients on all direct tax aspects regarding deal structuring, maintenance, reorganisations and exit planning. He also holds the titles of Head of Transfer Pricing and of the German Desk.

Oliver is the author of more than 250 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/ATAD 2), reporting obligations of tax intermediaries (DAC6), 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 also a regular speaker at conferences as well as being a lecturer with Legitech and ILA.

Oliver is qualified as a Chartered Accountant in Luxembourg ("Expert-Comptable") and is 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.

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