Agenda Day 3 Track 1
Friday, 19 June 2026
Track 1:
Structuring Tech Investments
This full-day track includes four key sessions outlining the latest regulatory requirements and trends affecting tech investment and structuring in Europe, from the perspective of a regulated fund as well as any startup or scaleup.
Session 1: AIFMD II and Fund Regulation & Governance
Session 2: EU Digital Regulation & Investment Risk
Session 3: Tax, Transfer Pricing, Substance & IP
Session 4: ESG & Non-financial Reporting
Session 1: AIFMD II and the New Supervisory Reality for Investment Funds
This masterclass examines how European fund regulation is entering a new supervisory phase, shaped by AIFMD II, ESMA convergence, and intensified scrutiny of delegation, liquidity, valuation, and oversight models. The session focuses on how these developments affect the survivability, economics, and credibility of tech and growth funds in practice. The session includes a strategic case study on MiCA, illustrating how EU regulation can rapidly re-base entire technology sectors and what this implies for investors, fund managers, and portfolio companies operating in increasingly regulated digital markets.
1.1 AIFMD II and Supervisory Expectations in Practice
09:35 - 09:50
Speaker TBA
This speech examines how AIFMD II is reshaping expectations around delegation, substance, and governance, and how ESMA-led supervisory convergence is narrowing the range of defensible fund manager models. The discussion addresses delegation thresholds, substance requirements, and the growing risk of “letterbox” structures being challenged in practice.
1.2 Governance, Liquidity, Valuation and the Economics of Compliance
09:50 - 10:10
Speaker TBA
This central intervention examines where fund governance frameworks are most likely to come under pressure as regulatory scrutiny intensifies. It brings together liquidity risk management in illiquid technology assets, valuation governance and oversight, the treatment and disclosure of side letters, and the changing role of depositaries. The discussion also addresses the real and rising cost of compliance.
1.3 MiCA as a Stress Test: When Regulation Re-Bases a Technology Sector
10:10 - 10:30
Speaker TBA
The final contribution reframes MiCA as a case study in how the European Union now regulates technology at infrastructure level. Using MiCA as an illustrative stress test, the presentation explores why such regulation matters to investment funds as much as to operating companies, how licensing and passporting reshape company geography, and why Revolut-style regulatory re-basing is becoming increasingly common. The session concludes by drawing broader lessons for AI, fintech, and platform investments operating in regulated digital markets.
Panel Discussion
10:30 - 11:00
Morning Coffee Break
11:00 - 11:30
Session 2: EU Digital Regulation and Technology Investment Risk
This masterclass examines how the European Union’s expanding digital regulatory framework is reshaping technology investment risk, due diligence, and governance expectations. The session focuses on how rules such as DORA, the EU AI Act, and the Digital Services framework increasingly affect business models, valuation, operational resilience, and exit readiness. The discussion is designed for investors, fund managers, and founders seeking to understand how digital regulation now interacts directly with capital allocation decisions.
2.1 DORA: When Technology Risk becomes Investment Risk
11:40 - 11:55
Speaker TBA
This speech focuses on the Digital Operational Resilience Act (DORA) and its implications for technology companies and the funds that invest in them. It examines how cyber risk, ICT outsourcing, third-party dependencies, and operational resilience are now subject to formal governance and testing requirements, and how these issues affect investor due diligence.
2.2 The EU AI Act: Governance, Liability, and Strategic Constraints
11:55 - 12:15
Speaker TBA
This intervention explores the EU AI Act as a new layer of structural risk for AI-driven business models. The discussion focuses on risk classification, governance obligations, data and model accountability, and the implications for product design, scalability, and time-to-market. Rather than legal mechanics, the emphasis is on how AI regulation affects investment theses and long-term defensibility.
2.3 The Digital Services Act: Regulatory Friction in Scaling Models
12:15 - 12:30
Speaker TBA
This speech examines the growing regulatory constraints affecting digital platforms, data-driven services, and technology intermediaries. It addresses obligations related to data governance, transparency, user protection, and conduct, and how these obligations increasingly shape scaling strategies and cross-border expansion.
Panel Discussion
12:30 - 13:00
Lunch Break
13:00 - 14:00
Session 3: Tax, IP, and Substance in Technology Investment Structures
This masterclass examines how tax, intellectual property, and substance requirements increasingly shape the viability and durability of technology investment structures. As regulatory scrutiny intensifies across Europe and beyond, traditional optimisation-driven approaches are giving way to frameworks that emphasise economic reality, value creation, and long-term defensibility. The session focuses on how transfer pricing, IP ownership, substance, transparency, and emerging European structuring options interact in practice — and why these issues now surface in tax audits, due diligence, fundraising, and exit processes.
3.1 Substance & Transfer Pricing: From Formal Compliance to Economic Reality
14:05 - 14:20
Speaker TBA
The opening contribution addresses the shift from formalistic compliance toward substance-based assessment in transfer pricing and group structuring. It examines how tax authorities increasingly evaluate where value is genuinely created, how decision-making authority is exercised, and whether profit allocation reflects operational reality. Particular attention is given to technology groups with distributed teams and cross-border development models.
3.2 Holding Structures, Transparency, and Beneficial Ownership
14:20 - 14:35
Speaker TBA
This segment examines the evolution of holding structures under expanding transparency, KYC/AML, and beneficial ownership requirements. It addresses how fund-level, portfolio-level, and founder-level structures are assessed by banks, regulators, and counterparties, and why certain legacy approaches are becoming harder to maintain in practice.
3.3 The 28th Regime and Societas Europaea (SE): Toward a European Operating Structure
14:35 - 14:50
Speaker TBA
This speech provides an update on emerging efforts to create a more unified European corporate framework through the proposed “28th Regime” and the use of the Societas Europaea (SE). It explores what these structures are designed to achieve, how they differ from traditional national company forms, and where they offer practical advantages for technology companies and investors.
3.4 IP Ownership, DEMPE, and Value Creation in Technology Companies
14:50 - 15:05
Speaker TBA
This presentation explores the treatment of intellectual property under EU tax and regulatory frameworks. It examines how IP ownership and control are assessed in practice, how R&D activity affects profit attribution, and why misalignment between legal ownership and operational reality creates risks for investors and acquirers.
Panel Discussion
15:05 - 15:30
Afternoon Coffee Break
15:30 - 16:00
Session 4: Tax, IP, and Substance in Technology Investment Structures
This masterclass examines how tax, intellectual property, and substance requirements increasingly shape the viability and durability of technology investment structures. As regulatory scrutiny intensifies across Europe and beyond, traditional optimisation-driven approaches are giving way to frameworks that emphasise economic reality, value creation, and long-term defensibility. The session focuses on how transfer pricing, IP ownership, substance, transparency, and emerging European structuring options interact in practice — and why these issues now surface in tax audits, due diligence, fundraising, and exit processes.
3.1 Substance & Transfer Pricing: From Formal Compliance to Economic Reality
14:05 - 14:20
Speaker TBA
The opening contribution addresses the shift from formalistic compliance toward substance-based assessment in transfer pricing and group structuring. It examines how tax authorities increasingly evaluate where value is genuinely created, how decision-making authority is exercised, and whether profit allocation reflects operational reality. Particular attention is given to technology groups with distributed teams and cross-border development models.
3.2 Holding Structures, Transparency, and Beneficial Ownership
14:20 - 14:35
Speaker TBA
This segment examines the evolution of holding structures under expanding transparency, KYC/AML, and beneficial ownership requirements. It addresses how fund-level, portfolio-level, and founder-level structures are assessed by banks, regulators, and counterparties, and why certain legacy approaches are becoming harder to maintain in practice.
3.3 The 28th Regime and Societas Europaea (SE): Toward a European Operating Structure
14:35 - 14:50
Speaker TBA
This speech provides an update on emerging efforts to create a more unified European corporate framework through the proposed “28th Regime” and the use of the Societas Europaea (SE). It explores what these structures are designed to achieve, how they differ from traditional national company forms, and where they offer practical advantages for technology companies and investors.
3.4 IP Ownership, DEMPE, and Value Creation in Technology Companies
14:50 - 15:05
Speaker TBA
This presentation explores the treatment of intellectual property under EU tax and regulatory frameworks. It examines how IP ownership and control are assessed in practice, how R&D activity affects profit attribution, and why misalignment between legal ownership and operational reality creates risks for investors and acquirers.
Panel Discussion
15:05 - 15:30
Afternoon Coffee Break
15:30 - 16:00