EY - BEPS impact on the Real Estate Fund industry

EY Real Estate Webcast

BEPS impact on the Real Estate Fund industry

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The Organisation for Economic Co-operation and Development (OECD) released the final reports on the Base Erosion and Profit Shifting (BEPS) Action Plan on 5 October, 2015. These reports on the 15 BEPS focus areas reflect recommendations for significant changes in international tax laws and treaties. What are some of these BEPS developments that will impact the Real Estate Fund industry?

Following our very successful EY BEPS webcasts series, join members of our senior global Real Estate tax team to discuss:

  • The impact of BEPS Action 6 (“Treaty relief”) on the design of fund and investment structures
  • Changes to financing and underwriting of investments under BEPS Action 2 (“Hybrid mismatches”), Action 6 (“Treaty relief”) and Action 4 (“Interest deductions”)
  • Operational changes on Real Estate Funds in light of BEPS Action 7 (“Artificial avoidance of permanent establishment”)
  • Tax reporting and documentation requirements under BEPS Action 8-10 (“Transfer pricing documentation”) and Action 13 (“Country-by-Country reporting”)


EY - Dietmar Klos

Dietmar Klos


Dietmar Klos is the EY EMEIA FSO Tax Leader, based in Luxembourg. He is a seasoned tax professional with a long-standing track record of top-level client service. He has more than 22 years of experience in Luxembourg advising corporate multinationals and starting from 2004 mainly Real Estate and Private Equity funds on international tax aspects as well as international merger and acquisitions.

Dietmar earned his tax law degree from University of Saarbrücken in Germany.

EY - Thomas Eckhardt

Thomas Eckhardt

Thomas Eckhardt is a leading member of Ernst & Young LLP’s German Tax Desk in New York. He is responsible for German tax law subject matters, with a focus on German reorganization and international tax law issues.

In this role, Thomas advises clients on U.S./German cross-border transactions. He has advised US groups and private equity investors on numerous large German reorganization projects as well as U.S. strategic and financial buyers or sellers on major acquisitions and dispositions of German companies and real estate assets.

Prior to joining EY in 1997, Thomas was an international tax advisor in the U.S. He was admitted as an Ernst & Young GmbH (Germany) partner in 2001. Thomas received his legal degrees from the University of Frankfurt (German JD) and New York University (LLM Taxation). He is a licensed German tax advisor and is admitted to the German bar.

EY - Jose Antonio (Jano) Bustos

Jose Antonio (Jano) Bustos

Jose Antonio (Jano) Bustos is a member of Ernst & Young LLP’s International Tax Services Practice and Global Tax Desk Network, based in New York. Jano has over 16 years of International Tax and Transfer Pricing experience.

Before joining EY, Jose had different outstanding posts at the Spanish Tax Administration, such as Senior Tax Inspector of the International Taxation Central Unit of the Spanish Tax Agency and Deputy Director General for International Fiscal Affairs, dealing with international taxation and transfer pricing audits, international advance price agreements and mutual agreement procedures and the negotiation of double tax treaties.

EY - Pablo Ornelas

Pablo Ornelas

Pablo Ornelas is a Senior Manager in Ernst & Young LLP’s Financial Services Transfer Pricing practice. In this role, Pablo has substantial experience in the Real Estate sector, advising on a wide range of transfer pricing issues.

Pablo has 15 years of experience and currently provides a range of international tax planning, transfer pricing planning and global transfer pricing documentation compliance as well as controversy support primarily in the real estate, asset management, pharmaceutical and technology industries.

He has a particular focus on intercompany leasing, intercompany services and cost allocations, intangible property migration and supply chain management. Pablo has been part of due diligence teams in the real estate, software, technology, health sciences, financial services and manufacturing industries. He has extensive experience with global transfer pricing risk assessment and compliance.

Pablo earned his Masters in Finance from Boston College.


EY - Jan Karel Weststrate

Jan Karel Weststrate

Jan Karel (JK) Weststrate is a Partner in the International Tax Practice of Ernst & Young LLP in the UK, based in London. He advises clients who are active in the real estate and asset management industry on a variety of tax matters including fund structuring, transactions and the implementation of processes and controls for tax risk management. JK has 19 years of experience in international tax, working at the member EY firms in the Netherlands, the US and the UK and in-house at a major global investment bank.

JK earned his LLM from Leiden University in the Netherlands.

EY - Marja Lutsep

Marja Lutsep

Marja Lutsep is the real estate sector leader for the Ernst & Young LLP Central Region’s International Tax Services Practice. In this role, Marja advises clients about the fund structuring and operations, from the international tax aspects to the development of processes and controls for tax risk management. She has 20 years of experience in tax, working at EY and in-house at a major New York-based global investment bank.

She also advises non-U.S. clients on investing into the United States, having worked with clients in the real estate and financial services industries.

Marja earned her J.D. from Duke University School of Law.