Raymond Krawczykowski, Deloitte

Raymond Krawczykowski Raymond is a Tax Partner. He joined Deloitte Luxembourg in 2004 and is specialised in Business Tax and M&A transactions. He leads the Tax department of Deloitte Luxembourg since 2012 and he is a Member of the Executive Committee of the Luxembourg firm since 2010. His areas of activities include Asset Management, Alternative Investment Funds, Banking and Cross-border tax transactions. Before joining Deloitte, Raymond was an International Tax Director at EY London (2002 until 2004). Raymond started his career at Arthur Andersen Luxembourg in 1994 as a Tax advisor and worked in London between 2000 and 2002 for Andersen London in the Financial Service Department. He is also leading the Tax working group for alternative investment managers at the Luxembourg Investment Funds Association. He holds a degree in Business and Tax laws from HEC Liege and an executive MBA from London Business School.

Agenda

10.05-11.05

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)

14.05-15.00

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)

16.15-16.45

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

16.45-17.45

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:

  • ALFI FAQs
  • 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

 


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