MLPs are interesting topic.
Frankly haven’t found any EU source to confirm what/how should be taxed.
But from Canadian PoV, MLP are heavily taxed.
But for Canadian investors, the tax treatment is quite different. Canadian investors in an MLP with U.S. assets are generally considered to be engaged in a business in the United States. The result is that the MLP will withhold 39.6 per cent tax on any distributions paid to non-resident, non-U.S. citizens
US & Canada have tax treaty btw.
So I am still confused on how in reality EU investors should be taxed against US MLPs. On top there is K1 filling which is US taxation, currently also no implications to EU investor, but who knows if you decide to visit US one day.
With that said, I have found few gaps in T212 taxation in past, so I wouldn’t rule out that this 0% taxation is a gap as well.