Christina is a Partner in the International & Corporate Tax department at ATOZ, having joined the group in 2015. A tax professional since 2008, Christina has experience in structuring Pan-European alternative investment funds across all asset classes, as well as coordinating tax structuring advice and implementation for institutional investors. She advises a wide range of international clients on direct tax aspects of cross-border transactions, set-up of investment structures, reorganisations and exit planning. Christina is a Chartered Accountant in Luxembourg (“Expert-Comptable”), holds a post-graduate degree in Luxembourg tax, a degree in Business Administration with a specialisation in Tax from Europa Universität Viadrina in Frankfurt and a Master II in Business Administration from Reims Management School, France. She speaks German, English and French.
The investment fund and asset management industry is highly regulated. UCITS, AIFs and their subsidiaries, as well as investment managers operate in accordance with EU directives and regulations. They are tax-neutral entities that generally operate on a pan-European basis and are used for pure investment purposes. They provide an essential platform for EU and non-EU investors to channel capital in particular to EU entities in a regulated manner. In this context, economic substance derives from EU Directives and the rules set by the competent national authorities that shape their operational set-up. In the context of tax rules, however, the perception may be somewhat different. The panel will present and discuss the concept of "substance" in investment fund structures and in the asset management business model(s) seen from a tax perspective including, inter alia, the potential impacts of the draft "Unshell" Directive, the influence of case law and of the increasing use of new ways of working.
Director
Managing Director
Partner
Avocat à la Cour - Partner