The importance of Substance in the post-BEPS era

• Overview of the notion of substance 

• Analysing the importance of substance in international tax

• • Requirements from a Luxembourg tax and regulatory perspective

  • Requirements from a foreign tax perspective

  • Requirements from a tax treaty perspective

  • Requirements from a transfer pricing perspective

  • Reputational risks

• Considering typical substance models

• • Master holding company

  • Management or service company

  • Outsourcing model

• Practical case studies: Defining the right level of substance