ATOZ Briefings | Structuring Alternative Investments in the post-BEPS era - Private Equity Focus


ATOZ Briefings are seminars offered by ATOZ to make sure that our clients are ahead of the curve on specific topics which affect their area of business.

On Tuesday 14 November, ATOZ Briefing Structuring Alternative Investments in the post-BEPS era" with a focus on Private Equity, was hosted by Oliver R. Hoor, ATOZ Tax Partner & Head of Transfer Pricing.

Agenda points included:

  1. Overview of the OECD BEPS Project and its implementation across Europe and beyond
  • EU Anti-Tax Avoidance Directive (ATAD & ATAD 2)
  • Multilateral Instrument (MLI)
  • OECD Transfer Pricing Guidelines

      2. Analyzing the practical impact of the different BEPS measures on investment structures

  • Hybrid mismatch arrangements
  • Principal Purpose Test (PPT)
  • Permanent establishments
  • Substance requirements
  • Transfer pricing documentation

     3. Considering structure alignments in view of future developments


For more information about ATOZ Briefings, please contact events [at] atoz [dot] lu (subject: ATOZ%20Bagel%20Briefings)