Cross-border structures between Germany and Luxembourg continue to be very popular.
Not least due to favorable regulatory conditions, Luxembourg is a common way for international investors to bundle their investments in the EU (and Germany).
From a tax perspective, however, these structures have increasingly been challenged by tax authorities in the recent past. In addition to typical private equity
and real estate structures, this also affects the recognition of intra-group financing and the general question of the creation of permanent establishments.
The event is co-organised with the German law firm Flick Gocke Schaumburg.
Program:
5:00 pm: Welcome address
5:10 pm: Start of the conference
Tax update: Current issues in real estate structures
• Viability of typical real estate structures
• Risks and common lines of argumentation
Tax update: Financing in private equity structures
• Interest deduction limitations
• Arm’s length transfer pricing for cross-border financing transactions
Tax update: Nexus for permanent establishments
• Server permanent establishment
• Service permanent establishment
• Permanent establishments through asset managers/service companies
• Cross-border activities of managing directors
6:30 pm: Get-together with snacks and drinks to round off the event
Speakers:
Dr. Christian Engelen
Partner at FGS
Christian.Engelen@fgs.de
Pol Mellina
Partner at BSP
pmellina@bsp.lu
Daniel Riedel
Partner at BSP
driedel@bsp.lu
Olivier Schank
Senior Associate at BSP
oschank@bsp.lu
Prof. Dr. Vassil Tcherveniachki
Partner at FGS
Vassil.Tcherveniachki@fgs.de
We look forward to discussing these issues from a German and Luxembourg perspective, and to answering any questions you may have.
Participation in the event is free of charge.
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