Tax

Blended learning

Level reached

Intermediate

Duration

 8,00 hours(s)

2 sessions of 4h

Language(s) of service

EN

Next session

Who is organizing this training?

The LPEA's mission is to represent, promote and protect the interests of the Luxembourg Private Equity and Venture Capital industries. Our trainings: PE & VC foundation courses, the Legal Academy by Allen & Overy, trainings on ESG, Valuations, Risk Management, Fund of Funds and new modules on AML/KYC and on Secondaries.

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Goals

8 hours in total, and 2 different sessions with theory and case studies around Tax.

  • The 1st session focuses on giving an overview on interest deduction limitations rules in Luxembourg and ATAD 2 anti-hybrid related measures.
  • The 2nd one focuses more in tax considerations in PE Investment structuring, tax obligations and recent case law developments.

Contents

Session 1:PE Investment – key Luxembourg tax structuring aspects: overview of interest deduction limitations rules in Luxembourg and ATAD 2 anti-hybrid related measures.

Typical PE investments structures and key Luxembourg tax considerations:

  • Interest deduction limitation rules in typical investments structures (focus on ATAD I, thin capitalization rules, transfer pricing requirements, recapture rule, etc), and
  • ATAD II anti-hybrid related measures (in Luxembourg and the investment jurisdiction)
Session 2:Tax considerations in PE Investment structuring, tax obligations and recent case law developments.
  • Overview of general and specific anti-abuse provisions, substance and beneficial ownership requirements in PE structuring
  • Luxembourg tax obligations for PE investment structures – DAC 6, CBCR and Pillar 2
  • Recent case law review impacting PE structuring

Teaching methods

Onlive, live session with Q&A.

Certificate, diploma

Certificate of completion and CPD points.

Course material

All the sessions will be recorded.

Organization contact details

Luís Galveias