Impacts of the Tax Reforms on the Structuring of Alternative Investment Funds - ATAD, DAC 6,...

Participants must have completed the General Accounting Fundamentals module or have equivalent professional experience.

Upon successful completion of this course, the participant should be able to:

• have an understanding of how cross border private equity and real estate investments are structured via Luxembourg
• have an overview of the BEPS recommendations, the European Anti-Avoidance Directives and the Multilateral instrument regarding tax treaties impacting Alternative Investment structures
• understand the importance of substance, beneficial ownership 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 European anti-avoidance directives (ATAD 1 and ATAD 2)
• BEPS measures and their impact on Alternative Investment structures
• Determining and organizing the right level of substance & beneficial ownership requirements depending on the countries of investments
• Optimizing set-ups in the new international tax environment
• Structuring aspects
• The importance of arm’s length conditions and transfer pricing documentation

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

The Lecturer is a Partner in the International & Corporate Tax department of the largest independent tax advisory firm in Luxembourg.
A tax professional since 2011, the lecturer has extensive experience in the structuring of alternative investments in Luxembourg (private equity, real estate, infrastructure and private debt) as well as related merger and acquisitions transactions. The lecturer has vast experience in providing direct tax advice for fund set-up, deal structuring, carried interest and cross-border operations. She also provides advice to family offices and high net worth individuals.