Foreword

Some may be under the impression that substance is a widely known tax concept and that there is not much to say about it.

Substance, however, is a constantly changing concept. It evolves with tax laws, jurisprudence, and doctrine, and has recently changed again with the principal purpose test (PPT) introduced by the OECD in Action 6 of their anti-base erosion and profit shifting (BEPS) plan.

For this survey, we decided to put theoretical discussions aside and focus only on factual elements, providing a snapshot of the current alternative funds landscape in Luxembourg. We surveyed 62 General Partners (GPs) with a Luxembourg office that are managing various asset classes such as private equity, private debt, real estate and infrastructure.

We are delighted to share our results with you.

 

Explore the results by selecting a topic below. You can also navigate to any page of the survey results using the table of contents on the left.

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