Laetitia Borucki of Bonn Steichen & Partners believes fund managers should review the potential tax impacts relating to residency, VAT and carried interest that are included in Luxembourg’s draft law to implement the EU Alternative Investment Fund Managers Directive. The creation of a new type of partnership is also to be considered.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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