Tax

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.

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

Onlive, live session with Q&A.

Certificate of completion and CPD points.