Raymond Krawczykowski, Deloitte

Raymond Krawczykowski Raymond is the head of tax at Deloitte Luxembourg. He has over 20 years of tax experience and leads the Deloitte Tax Private Equity practice. He advises clients on a wide variety of international tax issues, including mergers and acquisitions, assistance with structuring acquisitions and tax structuring of infrastructure funds for private equity houses.

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)

14.05-14.50

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)

16.05-16.50

Brexit and the US Tax Reform

  • A new international tax landscape?
  • Impacts for Luxembourg

16.50-17.50

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