On 12 July 2016, the EU Anti-Tax Avoidance Directive (ATAD, as amended by ATAD 2) has been adopted that requires EU Member States to implement as from 2019 certain anti-tax avoidance rules in their domestic tax law. These rules follow the recommendations made by the OECD and G20 in October 2015 in regard to Base Erosion and Profit Shifting (“BEPS”) and apply to all taxpayers that are subject to corporate tax in an EU Member State as well as EU permanent establishments of taxpayers which are not as such in the scope of the Directive.
More precisely, the ATAD lays down anti-tax avoidance rules in the following fields:
The measures provided in the Directive are presented as minimum standards. Therefore, EU Member States may implement more strict rules (e.g. lower safe harbour rules). Moreover, ATAD provides for a number of implementation options (safe harbours, grandfathering rules, etc.) where EU Member States can pick and choose from.
The options chosen by Luxembourg are all pro-business and, therefore, positive for the competitiveness of the Grand-Duchy. However, some of these rules have the potential to significantly impact Alternative Investments (Private Equity, Real Estate, etc.) structured via Luxembourg and Multinationals with an investment platform in Luxembourg.
This workshop aims at providing participants with a clear overview of the 2019 tax reform and analyses the different anti-avoidance measures in practical case studies.
Objectives of the workshop
Upon successful completion of this workshop, the participants will:
DRH / Transfer Pricing
Tax practitioners working for in the Alternative Investment Fund industry (Private Equity, Real Estate, etc.) and Multinationals ». However, obviously these tax developments may be interesting for other profiles as well.
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Oliver R. Hoor is a Tax Partner in the International and Corporate Tax Department of ATOZ. He is also heading the transfer pricing practice and the German desk of ATOZ.
His professional qualifications include the Luxembourg Certified Accountant (Expert Comptable) and the German Certified Tax Advisor (Steuerberater). He holds a degree in business administration with a major in tax from the University of Applied Sciences of Trier (Germany).
Oliver has more than 15 years of practical experience in Luxembourg and international taxation with a focus on Alternative Investments (Private Equity, Real Estate, Sovereign Wealth Funds, Hedge Funds and Securitization), Mergers & Acquisitions and Multinational Groups.
Oliver has published more than 170 articles and books on Luxembourg and international taxation, including, in particular, transfer pricing, the OECD Base Erosion and Profit Shifting (“BEPS”) Project, the OECD Model Tax Convention and tax treaties, EU Law and the State Aid investigations of the EU Commission. Oliver is further a regular speaker at conferences and lecturer with Legitech and House of Training.
Andreas Medler is a Tax Director in the International and Corporate Tax Department of ATOZ. He has 8 years of experience in Luxembourg an international tax with a focus on Alternative Investments (Private Equity, Real Estate, Sovereign Wealth Funds), banks and multinational groups. He is further a member of the Core Transfer Pricing Team of ATOZ. His professional qualifications include the German Certified Tax Advisor (Steuerberater).
La société Legitech a obtenu l’agrément du Barreau de Luxembourg.
Prix : 345€ HTVA
Tarif étudiant : 48,55€ HTVA, soit 50€ TTC (à condition d’envoyer une copie de sa carte étudiant et une attestation d’inscription)
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