Structuring Alternative Investments (Private Equity, Real Estate,…) in the post-BEPS era via Luxembourg

Upon successful completion of this course, the student will:

• have an understanding of how crossborder private equity and real estate investments are structured via Luxembourg
• have an overview of the BEPS recommandations, the European Anti-Avoidance Directive and the Multilateral instrument regarding tax treaties impacting Alternative Investment structures
• understand the importance of substance and arm’s length conditions when structuring investments
• have a clear view on how the changes of the international tax landscape will impact Alternative Investments

• Overview of Alternative Investments structures via Luxembourg
• The OECD BEPS Project and related actions at EU level
• BEPS measures and their impact on Alternative Investment structures
• Determining and organizing the right level of substance
• Optimizing set-ups in the new international tax environment
• Structuring aspects
• The importance of arm’s length conditions and transfer pricing documentation