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By Guilhèm BECVORT, Partner White Case S.à r.l.
Circular L.I.R. n°168quater/2 clarifies the CIV carve-out, bringing long-awaited certainty to RAIFs, SIFs and other Luxembourg funds.
Janus and the Double Face of Transparency
The Roman god Janus, guardian of transitions and thresholds, is traditionally depicted with two faces: one turned toward the past, the other toward the future. His ambivalence embodies the complexity of beginnings and endings, of openness and closure. The same image has haunted the reverse hybrid rule since its introduction under Luxembourg tax law and entry into force in 2022: depending on the angle of analysis, an entity could appear tax transparent under domestic law yet tax...
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