Hidden Dividend Distributions, Hidden Capital Contributions and Tax Adjustments under Art. 56 LITL
Objectives
After the training the participant shall be able to:
have a clear understanding of the concepts of hidden dividend distributions and hidden capital contributions
understand the importance of these concepts for Luxembourg companies
develop an understanding of the hierarchy of norms in regard to these concepts and Art. 56 LITL which is generally considered to formalize the arm’s length principle under Luxembourg tax law
have a view on the practical implications of tax adjustments made in accordance with these concepts and Art. 56 LITL
Programme
Introduction
Hidden dividend distributions
Characteristics of hidden dividend distributions
Tax treatment of hidden dividend distributions
Case studies
Hidden capital contributions
Characteristics of hidden capital contributions
Tax treatment of hidden capital contributions
Case studies
Triangular cases
Chain transactions
Transactions between sister companies
Complex cases
Case studies
Article 56 LITL
Scope of Article 56 LITL
Tax adjustments under Article 56 LITL
Hierarchy of norms
Case studies
Target audience
Professionals of the financial sector and in-house tax managers that would like to understand the importance of the concepts of hidden dividend distributions and hidden capital contributions as well as Article 56 LITL on Alternative Investments (Real estate, private equity, etc.) and multinational groups that manage their investments via a Luxembourg investment platform.
Certificate
At the end of the training, the participants will receive a certificate of attendance delivered by the House of Training.
Course material
The course material can be downloaded free of charge via your portal the day before the start of the course (download the Client Portal User’s Guide here).