Michel Lambion
Michel Lambion
Deloitte Tax & Consulting
Managing Director

Michel is Managing Director within the Indirect tax department in Luxembourg of Deloitte Tax & Consulting. He has over 25 years of experience in international Value Added Tax (VAT). Michel is focused on indirect tax issues (VAT, Registrations Duties) in the financial sector.  He is actively involved in tax policy activities including discussions of new legislations with the Luxembourg VAT autorities and the participation to the tax and VAT working groups of different professional associations.  

He is member of the Tax and Accounting Standing Committee of EFAMA.  He has been member of  the EFAMA VAT Task Force as from its creation in 2006 and its chair as from May 2007. He is the chair of the VAT working group of the Luxembourg fund association (ALFI) since its creation in 2003. He is also member of the VAT working group of the Luxembourg banking association (ABBL), Luxembourg Private Equity Association (LPEA), of the Luxembourg Capital Market Association (LuxCMA), of the Union of the Luxembourg Enterprises (UEL) and of the tax group of the Luxembourg British Chamber of Commerce.  He represents the Luxembourg Industry Federation (Fedil) with BusinessEurope and chairs its VAT in the Digital Age (ViDA) iniative Task Force.

Michel is a member of the Belgian Institute of Taxation Specialists (IAB / IEC) and a member of the Luxembourg branch of the International Fiscal Association (IFA).

He is a regular speaker at various national and international training courses and seminars and regularly publishs in different national and international newspapers and magazines.  He is a member of the Editorial Committee of the European Investment Fund Review.

He is a lecturer with the University of Luxembourg.

Before joining Deloitte in 2015, Michel built up expertise in various major consulting firms.

Michel has degrees in law and taxes from the “Université Libre de Bruxelles”, Brussels, Belgium,  in Luxembourg taxes from the “Chambre de commerce” of Luxembourg and a Master of Businnes Administration from ICN, Nancy University, France. His mother tongue is French and he is fluent in English.

Speaking at

Luxembourg
Tuesday, 24 October 2023
17.15 - 17.55
The concept of "substance" in investment fund structures and the asset management business models

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.

Astrid Barnsteiner
Astrid Barnsteiner
BDO Tax and Accounting

Director

Michel Lambion
Michel Lambion
Deloitte Tax & Consulting

Managing Director

Christina Leomy-Voigt
Christina Leomy-Voigt
ATOZ Tax Advisers

Partner

Geoffrey Scardoni
Geoffrey Scardoni
Clifford Chance

Avocat à la Cour - Partner