Ireland has recently improved its investment funds tax regime,
to offer investors an attractive tax transparent regulated limited
partnership vehicle. This development should be of particular
interest to private equity and real estate managers and investors.
It reinforces Ireland's position as a leading jurisdiction for
the establishment of investment funds, with over 5,000 regulated
funds domiciled in Ireland, holding over €1.3 trillion in
total assets.
Investment limited partnerships are a form of Irish regulated
investment fund. Legally, these limited partnerships are
transparent entities, with the partners jointly owning the assets
of the fund. Historically, however, these partnerships have been
treated as tax opaque under Ireland's tax code. The recent
development aligns their tax treatment with their legal treatment,
so that they are now tax transparent vehicles. Income and gains
arising in these funds are now treated for Irish tax purposes as
arising to the
