Flora Castellani, KPMG

Flora Castellani Flora Castellani joined KPMG Luxembourg in 2013 as head of the Tax technical team. Through her past practice, she developed an in depth expertise in corporate and international tax law. Flora is now also leading the BEPS team within KPMG Luxembourg. She is the author of several articles on Luxembourg corporate and international tax matters. Flora has more than 15 years of professional experience in corporate and international tax advice. She started her carrier as tax lawyer in a French law firm (in Paris), before moving to Luxembourg where she advised clients mainly active in the real estate industry. She gained further experience in Luxembourg and international corporate taxation as head of the technical team of a first ranking Luxembourg law firm. She is a member of several ALFI and EFAMA tax working groups.



EU Anti-Tax avoidance Directive (ATAD)

  • Understanding the ATAD measures: limitation of the deductibility of interest, general anti-avoidance rule, exit tax, controlled foreign companies rules, hybrid mismatches) and the OECD BEPS influence – Overview
  • how is it expected to modify the Luxembourg tax legislation
  • How will it impact Luxembourg investment funds – Walk through example(s)


Access to Double Tax Treaties for investment funds

  • General overview
  • Modifications introduced through the OECD BEPS initiative (in particular BEPS Action 6)
  • Consequences for Luxembourg investment funds (UCITS and AIFs)


Taxes and AML-Newly introduced links:

  • Introduction of a new tax offence in Luxembourg legislation
  • Tax offences as primary offences for AML,
  • Access by tax authorities to AML files of professionals – new EU Directive (DAC5)
  • Impact for the Luxembourg investment fund industry


Exchange of information

Exchange of Information

  • introduction on exchange of information in general and how it has evolved over the last few years

Common Reporting Standard:

  • Feedback on first reporting under Common Reporting Standard
    Country by Country Reporting:
  • Main features and scope
  • Country by Country Reporting for Luxembourg investment funds and funds’ structures

DAC 6 – automatic exchange of information in the field of taxation in relation to reportable crossborder arrangement:

  • New measures to be introduced and new obligations for advisors
  • Impacts for funds’ structures