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By Oliver R. Hoor (picture) and Keith O`Donnell, ATOZ *
On 9 January 2015, the Luxembourg tax authorities released a circular (Circular L.I.R. No. 14/4, the “Circular”) which provides guidance on the tax treatment of income derived by Luxembourg limited partnerships (SCS/SCSp). The Circular further confirms the municipal business tax (“MBT”) treatment of Alternative Investment Funds (“AIFs”), Specialized Investment Funds (“SIF”), Investment Companies in Risk Capital (SICARs) and SICAV Part II Funds established in the form of a Luxembourg limited partnership. This article analyses the tax treatment of Luxembourg limited partnerships and outlines the guidance provided in the Circular.
I. Introduction
On 12 July 2013, the Luxembourg...
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