Alternative Funds 2020 guide covers 19 jurisdictions. It discusses fund structures, cryptocurrencies and non-traditional assets, tax regimes, double-tax treaties, disclosure/reporting requirements, fund managers, permanent establishments, marketing, and the FATCA/CRS compliance regime.

Our experts Isabelle Lebbe, Pierre Beissel, Rodrigo Delcourt and Claudia Hoffmann are the authors of the Luxembourg's jurisdiction Chapter.

Last update: October 2020

Press & Media Download the Luxembourg Chapter here_

Press & Media Access the full guide online here_


1 General
1.1 General Overview of Jurisdiction

2 Funds
2.1 Types of Alternative Funds
2.2 Fund Structures
2.3 Regulatory Regime
2.4 Loan Origination
2.5 Cryptocurrencies and Non-traditional Assets
2.6 Regulatory Approval Process
2.7 Requirement for Local Investment Managers
2.8 Other Local Requirements
2.9 Rules Concerning Other Service Providers
2.10 Requirements for Non-local Service Providers
2.11 Tax Regime
2.12 Double-Tax Treaties
2.13 Use of Subsidiaries for Investment Purposes
2.14 Origin of Promoters/Sponsors of Alternative Funds
2.15 Origin of Investors in Alternative Funds
2.16 Destination of Investments Made by Alternative Funds
2.17 Key Trends
2.18 Disclosure/Reporting Requirements
2.19 Anticipated Changes

3 Managers
3.1 Legal Structures Used by Fund Managers
3.2 Regulatory Regime
3.3 Tax Regime
3.4 Rules Concerning “Permanent Establishments”
3.5 Taxation of Carried Interest
3.6 Outsourcing of Investment Functions/Business Operations
3.7 Local Substance Requirements
3.8 Local Regulatory Requirements for Non-local Managers

4 Investors
4.1 Types of Investor in Alternative Funds
4.2 Marketing of Alternative Funds
4.3 Rules Concerning Marketing of Alternative Funds
4.4 Local Investors
4.5 Regulatory Regime
4.6 Disclosure Requirements
4.7 Tax Regime
4.8 FATCA/CRS Compliance Regime


Updated EU list of non-cooperative jurisdictions for tax purposes: Three jurisdictions added

On 4 October 2022, the Council revised the EU list of non-cooperative jurisdictions for tax purposes (the “EU blacklist”) and added the Bahamas, Anguilla and Turks and Caicos in their conclusions.

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