Administrative Circular on Taxation of Luxembourg Limited Partnerships Is a Welcomed First Step

Luxembourg partnerships have proven to be very popular, notably with foreign actors in the private equity sector. While regulated partnerships formally benefit from broad tax exemptions, unregulated ones usually submit advance tax ruling requests confirming the absence of municipal business tax liability. A new circular issued in January 2015 provides certainty in this regard for unregulated partnerships which qualify as alternative investment funds, but does not fully lift the uncertainty for the remaining ones.