IQ-EQ CFO e-Lab: ATAD 2 / BEPS and its impact on Luxembourg-based private equity funds


IQ-EQ’s third webinar in our CFO eLab series, held on 6 October, focused on the impact that ATAD 2 / BEPS will have on Luxembourg-based private equity funds.

As moderator, I was honoured to be joined by two prestigious speakers:

  • Raymond Krawczykowski, Tax Partner with Deloitte Luxembourg focused on M&A transactions and alternative investment funds. He advises clients on a wide variety of international tax issues, including the tax structuring of infrastructure funds for private equity houses
  • Frank van Kuijk, Partner at Loyens & Loeff and member of the firm’s Investment Management and Tax practice groups in Luxembourg. He specialises in advising clients on the structuring of Luxembourg alternative investment funds with particular focus on private equity, real estate, infrastructure and debt funds

During the insightful session, Raymond Krawczykowski began by explaining how ATAD 2 provides a framework to tackle hybrid mismatches between associated enterprises in the EU and third countries. He ran through a number of key concepts provided for the anti-hybrid legislation before delving into the acting together and the 10% rule, and reverse hybrid rules.

Raymond then handed the reins to Frank van Kuijk, who talked our audience through detailed structure diagrams explaining ATAD 2’s impact on Luxembourg-based private equity funds, comparing pre-BEPS structures with the modern standard.

With over 100 attendees and lots of contributions to our questions box, it was a very lively and informative session. If you missed it, don’t worry! We are now pleased to share a video recording of the full session: 

You can also listen to the audio as a podcast, available via our website as well as Spotify, Apple Podcasts and Google Podcasts. Please click below to listen:

IQ-EQ CFO e-Lab: ATAD 2 / BEPS and its impact on Luxembourg-based private equity funds

More from IQ-EQ’s CFO e-Labs

IQ-EQ’s CFO e-Labs series is a specially designed programme of interactive ‘masterclass’ webinars based on the evolving needs of the private fund CFO. Click here to find out more about the series, and catch up on our previous CFO e-Labs below: