Implementation of ATAD 2 into Luxembourg Tax Law - Analysing the Impact on Alternative Investments and Multinationals

After the training the participant shall be able to:

• have a clear understanding of the complex anti-hybrid mismatch rules that will be effective as from 2020
• understand the impact of the new rules on Alternative Investments structured via Luxembourg
• understand how Luxembourg investment platforms of multinational groups might be impacted by the new tax measures
• have a view on structure alignments that might be implemented to manage the tax position in Luxembourg

• Overview of the Luxembourg tax reform
• Types of hybrid mismatch arrangements targeted by the new rules
  • Hybrid mismatches (hybrid financing instruments, hybrid entities, hybrid permanent establishments, etc.)
  • Reverse hybrid mismatches
  • Tax residency mismatches
• Mechanism of the anti-hybrid mismatch rules
• Limits of the scope of the new rules
• Case studies

At the end of the training, the participants will receive a certificate of attendance delivered by the House of Training.