Luxembourg Transfer Pricing Considerations For In-house AIFMs – New York Office Snippet

Loyens & Loeff New York regularly posts 'Snippets' on a range of EU tax and legal topics. This Snippet describes Luxembourg transfer pricing ('TP') considerations relevant for in-house alternative investment fund managers ('AIFM').

US fund sponsors raising capital in the EU via a Luxembourg special limited partnership ('SCSp') require the services of an EU-authorized AIFM to benefit from an EU marketing passport. AIFM services cover at least portfolio management and risk management (with the possibility to delegate one of the two and keep only oversight) and may include ancillary services such as valuation, marketing and fund administration.

In Luxembourg, US sponsors have the choice between hiring a third-party AIFM that already has an AIFM license or setting up their own licensed AIFM.