Ireland Tax Agency Issues Guidance on Tax Treatment of Investment Limited Partnerships

The Irish Revenue Commissioners April 29 issued Revenue eBrief No. 087/26, and guidance, on the taxation of investment limited partnerships (ILPs) under Taxes Consolidation Act 1997 (TCA). Topics covered include that: 1) general partners are personally liable for an ILP’s debts and obligations, while limited partners aren’t liable beyond their capital contribution; 2) ILPs authorized on or after Feb. 13, 2013, are considered tax-transparent for Irish tax purposes, with capital gains and losses arising to partners, and aren’t subject to the gross roll-up regime; 3) the excluded person exemption for withholding tax on dividend income applies to ILPs and specified ...