Implementation of ATAD 2 into Luxembourg Tax Law - Analysing the Impact on Alternative Investments and Multinationals

The training will provide you with a clear understanding of the complex anti-hybrid mismatch rules that are effective as from 2020 and the impact of the new rules on Alternative Investments structured via Luxembourg.

After the training the participant shall be able to:

• Have a clear understanding of the complex anti-hybrid mismatch rules that are effective as from 2020

• Understand the impact of the new rules on Alternative Investments structured via Luxembourg

• Understand how Luxembourg investment platforms of multinational groups might be impacted by these tax measures

• Have a view on structure alignments that might be implemented to manage the tax position in Luxembourg.

• Overview of the Luxembourg anti-hybrid mismatch rules 
• Types of hybrid mismatch arrangements targeted by the new rules
• • Hybrid mismatches (hybrid financing instruments, hybrid entities, hybrid permanent establishments, etc.)
  • Reverse hybrid mismatches
  • Tax residency mismatches
• Mechanism of the anti-hybrid mismatch rules
• Limits of the scope of the new rules
• Case studies

Professionals of the financial sector and in-house tax managers that would like to understand the potential impact of the anti-hybrid mismatch rules on Alternative Investments (Real estate, private equity, etc.) and multinational groups that manage their investments via a Luxembourg investment platform.

The lecturer is a Principal in the International and Corporate Tax department with a large tax advisory firm in Luxembourg.

A tax professional since 2011, the lecturer worked in the accounting sector for 2 years in France before focusing on international tax in Luxembourg. The lecturer has experience in relation to the structuring of Alternative Investments via Luxembourg (private equity, real estate, hedge funds, debt funds, etc.) as well as mergers & acquisitions (multinational groups). The lecturer advises clients on all direct tax aspects regarding deal structuring, maintenance, reorganisations and exit planning. The lecturer is a member of the Core Transfer Pricing Team of an independent advisory firm.

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