Loyens & Loeff advised Patrizia Immobilion sells residential portfolio consisting of 306 homes

US fund managers raising capital in the EU often set up a Luxembourg special limited partnership (SCSp) qualifying as an alternative investment fund (AIF). An SCSp is transparent for Luxembourg tax purposes, unless the reverse hybrid rules (RH Rules)

This Snippet has been written in collaboration with Darren Gorman and Ard Crebas of Waystone.  

The Luxembourg tax authorities published a second circular on the application of the reverse hybrid rules (LIR 168quater/2). Our specialists break down the information and impact.