Members of our New York based team contributed to Taxnet Pro – Thomson Reuters Canada Corporate Finance Journal, focusing on the impact of reverse hybrid rules on the investment fund industry.
Over the past few years, Luxembourg has become the main entry point when it comes to raising capital from European professional investors. This position is notably due to its special limited partnership (société en commandite spéciale) ('SCSp'). The SCSp is the go-to legal form when it comes to setting up an unregulated alternative investment fund. While this vehicle is tax transparent and should generally not generate any issues from a tax perspective, it may be different if anti-hybrid rules apply.
Our specialists delve into the concept of reverse hybrid rules, alongside discussing the collective investment fund carve-out, defining the investor concept, and sharing practical experience with the RH Rules.
You can read the full article on Taxnet Pro.
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