On 8 August 2019, the Luxembourg legislator released the draft law implementing EU Directive 2017/952 of 29 May 2017 (the “Anti-Tax Avoidance Directive 2” or “ATAD 2”). This measure builds on the extensive work done over the past two years to tackle corporate tax avoidance and ensure fair and effective taxation in the EU. ATAD 2 will ensure that hybrid mismatches of all types cannot be used to avoid tax in the EU, even where the arrangements involve third countries.
The new rules will come into force on January 1, 2020. The application of these provisions is expected to have effects on private equity or real estate funds. Taxpayers and their service providers will have to assess impact on existing investment structures, detect potential hybrid mismatches and where necessary, implement structure alignments before year-end.
This conference aims at providing participants with a comprehensive overview of the new rules and how they may impact Alternative Investments and multinational groups in Luxembourg.
Our clients/contacts can have a discount of 25% on the conference registration (max 5 people).
To benefit of the discount, please use the code « BSP-25-231019 » when registering on the website (the offer cannot be combined with other promotions).
08h15 Registration & Welcome coffee
09h00 Opening of the conference by the President of the conference - Mr André Vasanne, MEETINCS S.A. Moderator of the day – Laurent Engel, Tax partner - FICEL Group
09h15 ATAD 2 for starters: Key concepts and provisions - Mr Daniel Riedel, Senior Associate - BSP
10h05 A focus on the financial instruments rule: How to identify the situations in scope ? What are the links with the multiplication of tax credits (cum-ex situations)?
Which are the carve-outs? - Mr Laurent Engel, Tax Partner - FICEL Group
10h55 Coffee break
11h15 A focus on the hybrid entity rules - Mrs Johanna Tschurtschenthaler, Senior Associate – Allen & Overy
12h05 Déjeuner-Networking 1ere partie
14h00 Case studies – what is the impact of the bill and how to prepare? PE/RE investment funds – insights into the new business landscape: ‘acting together’, reverse hybrids, … - Mrs Sandrine Degrève, Head of Tax Technical Team - KPMG Luxembourg
14h50 Coffee break
15h10 Case studies – what is the impact of the bill and how to prepare? Corporates and multinationals – Assessing the risks in a waterfall of complex situations - Mrs Laetitia Borucki, Counsel – AKD Luxembourg
16h00 How to put it into practice (panel) - Mrs Laetitia Borucki, Mrs Sandrine Degrève, Mr Daniel Riedel, Mrs Johanna Tschurtschenthaler and as special guests : Mrs Flora Castellani - UEL, Mr Giuliano Bidoli, Company Director - BC Partners
17h00 End of the conference