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Our tax specialists keep you up to date on the latest developments affecting the regulatory tax landscape and share their in-depth analysis of current trends.
IBOR transition – Transfer pricing implications of inter-bank rates transition
One of the most important changes to affect the financial services sector is now closer than ever.
VAT for funds: beyond the exemption for fund management services, do other methods exist to improve the VAT position of investment funds?
In principle, a fund should be tax neutral: only investments and investors should be taxed.
Digital transformation is inextricably linked with our era and is at the heart of the resilience enterprise strategy.
Building a digitally savvy workforce within the tax function
The struggle to source the right talent and the considerable changes to the very nature of work has left organizations recognizing the need to upskill their workforce.
Tax assessments in Luxembourg
In recent years, Luxembourg has recorded a continued increase in the number of claims filed by corporate taxpayers with respect to direct tax decisions.
Tax versus agile methodologies—friends or foes?
In recent years, agile methodologies have significantly increased in popularity due to their flexibility and customer-centric approach. Having proved their efficiency, these methodologies are now used in a diverse range of projects, vastly diverging from their original application—the development of digital tools and software.
Cash management solutions for asset managers
In these unprecedented times, it is more crucial than ever for asset managers to maintain flexible business operations and adequate cash positions.
How tax administrations and tax specialists are going digital ?
Digitalization, new technologies and digital business models are now the major building blocks of our lives and economies.
Impact and Uncertainties of the New France-Luxembourg Double Tax Treaty on Real Estate Investment Structures
On 20 March 2018, the governments of Luxembourg and France signed a new double tax treaty and its additional protocol to replace the 60-year-old agreement between the two countries.
Will Spain apply the multilateral instrument more intensively after COVID-19?
Amid the COVID-19 pandemic, Spain, whilst undertaking considerable efforts to keep its population safe, is also trying to keep its economy alive.
Asia fund managers and offshore platforms, a pair on a declining curve?
Over the past decades, the Asia Pacific region has developed rapidly and become a renowned playground for worldwide investors.
Cause and effect: the future of the infrastructure fund
Over the last decade, we have witnessed a stream of record-breaking events in terms of both fund raising and deal size within the infrastructure funds sector.
The impact of ATAD II on real estate asset managers
The EU Council approved Directive 2017/952/EU (ATAD II or the “Directive”), which amended ATAD I. The ATAD II aims to extend the scope of ATAD I for hybrid mismatches involving non-EU countries.
How Senegal remained attractive after the COVID-19 pandemic
It is a known fact that Senegal, of all French-speaking African countries, undoubtedly offers a very welcoming environment for foreign investors thanks to the numerous advantages it provides. Senegal is very politically stable and has competitive production costs, a skilled workforce, advantageous geographic location and no restriction on full ownership of a business by foreign investors.
German controlled foreign corporation (CFC) reporting and alternative investment funds in light of ATAD 2
Alternative investment funds (AIF’s) are facing more and more challenges to fulfill all tax reporting requirements for their investors in the different distribution countries. New regulations like ATAD 2 and DAC6 as well as recent tax measures in response to COVID 19 will also bring significant changes on the tax reporting for the AIF fund industry.
AU:VAT and AIFs: how AIF structures can safely navigate VAT rules
Compared to traditional funds, alternative investment funds (AIFs) often use complex structures that require an in-depth VAT analysis. This is especially true for non-EU promoters setting up their first funds in EU jurisdictions.
Why are asset managers (privately) considering public real estate investment strategies?
Small things can have non-linear effects on a complex system.
While this sentence may not immediately resonate with the reader, the term “butterfly effect” (such as where a butterfly flapping its wings in, say, Mexico City, may trigger an earthquake or tsunami somewhere like, say, Japan) will surely be more evocative.
Revisiting transfer pricing in the alternative asset management sector
New concepts introduced by the Organization for Economic Cooperation and Development (OECD) as part of the Base Erosion and Profit Shifting (BEPS) initiative in 2015 ─ aimed at aligning taxation with the economic activity that generates profits ─ are fundamentally reshaping the international tax landscape.
How to manage substance in a home working environment
As the uncertainty continues over how long office closures and travel restrictions due to the COVID-19 pandemic will remain in place, the practical difficulties of holding physical board meetings in their required jurisdictions and other issues around substance have been brought into sharp focus.
What is the impact of COVID-19 on infrastructure deals?
The COVID-19 outbreak has had a major impact on the global economy and the infrastructure asset class is no exception.
This crisis is hitting several sectors as financing is scaled back and project closings are delayed, primarily as a result of uncertainty across financial markets.
New Era in the Alternative Investment Fund Industry through Tokenisation
In light of the current global health threat, the importance of reaching a new level of technological readiness to facilitate smooth remote working and to reshape the way business is carried out worldwide cannot be ignored. This unprecedented situation is expected to split the world and the available technology into “before and after” the COVID-19 lockdown.
A deep dive into Alternatives
New opportunities and areas of doubt have emerged in recent years with the rise of the alternative investments industry. This article is the first of three, which will give details on the concept of alternative investment funds (AIFs) and investment platforms from a Luxembourg direct tax perspective, the VAT aspects requiring consideration when dealing with AIFs and acquisition vehicles and transfer pricing issues in connection with the AIF and its organs and service providers.