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7,00 heure(s)

4 sessions of 1h45'

Langues(s) de prestation


Prochaine session


7 hours in total, and 4 different sessions with theory and case studies around Tax.

  • The 1st session focuses on the impact of different BEPS measures, the European Anti-Tax Avoidance Directives and related Luxembourg tax law changes on contemporary PE investment structures.
  • The 2nd one focuses more in the importance of substance from different perspectives.
  • The 3rd session focuses on the transfer pricing and more specifically in the tax risks, documentation, best practices and other aspects around it.
  • The last session is all about MDR (Mandatory disclosure regime) taking into account the latest developments in Luxembourg, definitions and concepts around it.


Session 1: PE Investments in the post-BEPS era: Structuring aspects

1. Recap of the OECD BEPS Project
2. Tax rules applicable in Luxembourg and abroad
3. Analysis of tax treaty changes and implementation through Case study.

Session 2: PE Investments in the post-BEPS era: The importance of substance

1. The notion of substance
2. Substance requirements in international taxation from different perspectives

Session 3: Managing substance in practice

PE Investments in the post-BEPS era: Transfer pricing considerations
1. Snapshot of the Luxembourg transfer pricing landscape
2. The arm's length principle
3. Tax risks in relation to transfer pricing
4. Typical controlled transactions in Luxembourg
5. The new reporting obligations on intra-group transactions
6. The OECD Discussion Draft on transfer pricing aspects of financial transactions
7. The transfer pricing regime applicable to Luxembourg finance companies
8. Transfer pricing documentation
9. Best practice recommendations

Session 4: PE Investments in the post-BEPS era: The mandatory disclosure regime (DAC 6)

1. Key features of the disclosure regime
2. Arrangements, intermediaries and other interpretation issues
3. The hallmarks of reportable arrangements
4. The main benefit test - Developing a reasonable approach
5. Managing DAC 6 obligations in practice
6. Navigating between penalties
7. Implementation through Practical case studies

Méthodes pédagogiques

Online sessions with Q&A.

Certificat, diplôme

Certificate of completion and CPD points.