Luxembourg is a major financial centre and securitization transactions are an important element of the financial industry. Broadly speaking, securitization comprises the acquisition by a securitisation vehicle of various assets such as real estate loans, mortgages, auto loans, credit card debt obligations and the financing of these assets with the issuance of securities. The yield of the amounts to be paid to the investors in the securitization vehicle is linked to the yield generated by the underlying assets.
However, the legal and tax environment surrounding the Luxembourg securitization landscape is constantly evolving.
From a legal perspective, the coming into force in 2019 of Regulation (EU) 2017/2402 laying down a general framework for securitisation and creating a specific framework for simple, transparent and standardised (STS) securitisation will create a new framework for certain type of securitisations.
We will analyse the main features of Regulation 2017/2402 and how the current Luxembourg securitisation regime and the Luxembourg financial industry (including the Luxembourg service providers active in the securitisation field) might be impacted by the coming into force of this new Regulation.
As regards tax aspects, the OECD worked as part of its Base Erosion and Profit Shifting (“BEPS”) Project on the design of new tax rules to be implemented in domestic tax law and tax treaties. Within the EU, BEPS measures will need to be implemented by EU Member States in accordance with the EU Anti-Tax Avoidance Directive (ATAD/ATAD 2). The different measures that may affect both existing and new securitization transactions need to be implemented in 2019 and 2020. Thus, it has to be analysed whether structure alignment might be required in regard to existing investment structures and how new investments might be structured in an efficient manner.
Moreover, we have seen some developments in regard to VAT that may impact securitization vehicles. Given the strong ties between Luxembourg and London, the VAT consequences of the upcoming BREXIT may also be of interest when it comes to securitization transactions.
Upon successful completion of this workshop, the participants will:
banks, investment funds, insurance companies, management and mutual fund companies, legal, tax and financial officers, financial engineering managers, lawyers, consultants.
Adrian is the founding partner of Sedlo Law Firm, a Luxembourg based law firm specialising in financial law.
He has 20 years of experience in setting-up Luxembourg securitization vehicles and has worked for a long time in the Luxembourg offices of Anglo-Saxon “magic-circle” firms. He is well-known for his expertise in Luxembourg securitization law.
He has written several articles on different aspects of Luxembourg financial law as well as on the legal treatment of derivatives in Luxembourg.
He is an active speaker at financial industry events and provides training and courses on Luxembourg securitization law.
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 180 articles and books on Luxembourg and international taxation, including transfer pricing and 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 House of Training and Legitech.
Silvin has more than 5 years of experience in Luxembourg indirect tax advisory and compliance with a focus on Private Equity, Real Estate, Securitization transactions and Multinational Corporations.
He advises a wide range of international clients on Luxembourg indirect tax matters related to cross-border transactions, set-up of investment structures, acquisitions and divestitures.
Langue : Anglais
Cette formation d’une demi-journée est agréée par le Barreau de Luxembourg dans le cadre de la formation continue.
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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