To enhance its appeal as a financial hub, Luxembourg has unveiled a new carried interest tax regime aimed at attracting top-tier fund managers. The proposed legislation, Bill 8590, tabled by Prime Minister Luc Frieden and Finance Minister Gilles Roth, is set to take effect in 2026.
The initiative positions Luxembourg to better compete with cities like London and Paris, which already offer favourable tax regimes for private equity professionals. Until now, carried interest in Luxembourg was taxed as miscellaneous income, reaching rates up to 45.78%. The new system introduces two more attractive options:
Contractual Carried Interest – Fund managers can benefit from a reduced tax rate (approx. 11%) on performance-related bonuses, even without a personal investment. This new scheme removes the 10-year limitation of the previous transitional regime and applies permanently.
Carried Interest with Investment – When managers invest in the fund alongside clients and hold their stake for at least six months, distributions may be fully tax-exempt, aligning with capital gain treatment.
The reform also broadens eligibility to include individuals involved in fund management even if not directly employed by the AIFM, such as directors or external advisors.
Safeguards are built in to prevent abuse, including thresholds on investment size and anti-avoidance measures.
Finally, the bill clarifies the tax treatment of carried interest from transparent entities (e.g. SCSp, SCS), ensuring consistent taxation regardless of fund structure.
By combining reduced rates with legal clarity, Luxembourg hopes to attract decision-makers and reposition itself as not just an administrative domicile, but a true centre of investment management. If passed by parliament, the new regime will come into force in 2026.
If you are interested to know more about how the new tax benefits might benefit you, please contact Fabio Mastrosimone at f.mastrosimone@umawealth.com
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