Comparison table of Luxembourg investment vehicles

Publications 05 January 2025

Compare two vehicles:

	UCITS	Part II UCI	ELTIF	SIF	SICAR	RAIF	SPF	Securitisation vehicle	Unregulated SCS/SCSp	SOPARFI
English name/description	Undertakings for collective invesment in transferable securities	Part II Undertaking for Collective Investment	European long-term investment fund	Specialised Investment Fund	Investment Company in Risk Capital	Reserved Alternative Investment Fund	Private Wealth Management Company	Securitisation vehicle	Unregulated common limited partnership/special limited partnership	SOPARFI
Practical use	Highly regulated investment vehicle authorised by the CSSF and eligible for cross-border marketing within the EU under the UCITS passport, which may be marketed to retail, professional and institutional investors, subject to applicable requirements.	CSSF-authorised regulated investment vehicle used for investment strategies that fall outside the the UCITS eligibility criteria, including strategies involving less liquid or non-UCITS-eligible assets, while remaining subject to full CSSF product supervision.	EU long-term investment fund label applicable to investment vehicles investing in long-term assets forming part of the real economy, such as private equity, infrastructure, real assets and private debt, and designed to facilitate long-term investment strategies, including, subject to applicable conditions, access by retail investors.	CSSF-authorised regulated alternative investment vehicle reserved to well-informed investors and commonly used as an AIF for a broad range of alternative investment strategies, including private equity, hedge funds, real estate, infrastructure and private debt.	CSSF-authorised regulated investment vehicle dedicated to private equity, venture capital and other investments qualifying as risk capital, targeting the development and value creation of portfolio companies.	Alternative investment vehicle reserved to well-informed investors, used for the same range of alternative investment strategies as SIFs, including hedge funds, private equity, venture capital, real estate, infrastructure and private debt, and structured without prior CSSF product authorisation, with regulatory supervision exercised by the CSSF at the level of the authorised AIFM.	Unregulated investment vehicle used by individuals for private wealth structuring and the holding of financial assets, limited to passive asset management and excluded from any commercial or professional investment activity.	Investment vehicle used for securitisation transactions, including true sale and synthetic securitisations, securitisation of portfolios of securities or receivables (such as loans, leasing receivables and non-performing loans), securitisation of tangible and intangible assets, intra-group financing structures, and structured finance transactions such as collateralised loan obligations (CLOs), including, where applicable, actively managed structures.	Unregulated partnership investment vehicle commonly used for private equity, real estate, venture capital and other alternative strategies, offering significant contractual flexibility and frequently used in fund structuring, co-investment arrangements and carried interest vehicle structures.	Ordinary Luxembourg corporate vehicle commonly used for holding, financing and investment activities, including the holding of participations, intra-group financing, intellectual property holding and other investment activities, depending on the structure and purpose.
Applicable legislation	Law of 17 December 2010 - Part I (“UCITS Law”).	Law of 17 December 2010 - Part II (“UCI Law”).	Regulation (EU) 2015/760 of 29 April 2015 on European long-term investment funds (“ELTIF Regulation”), amended on 15 March 2023 . ("ELTIF 2 Regulation").	Law of 13 February 2007 (“SIF Law”).	Law of 15 June 2004 (“SICAR Law”).	Law of 23 July 2016 (“RAIF Law”).	Law of 11 May 2007 (“SPF Law”).	Law of 22 March 2004 (“Securitisation Law”).	Law of 10 August 1915 (“Company Law”).	Law of 10 August 1915 (“Company Law”).
Authorisation and supervision by the CSSF	Yes.	Yes.	Yes.	Yes.	Yes.	No.	No.	No, unless issue on a continuous basis of financial instruments offered to the public. The securitisation vehicle issues on a continuous basis when it carries out more than three issuances of financial instruments offered to the public during the financial year. All the issuances by the compartments should be added up. The issuance of financial instruments is offered to the public when it is not intended for professional clients, the denominations are less than EUR 100,000 and it is not distributed as private placement.	Non.	Non.
Qualification as an AIF	No.	Always an AIF.	Always an AIF.	Yes, unless it falls outside the AIF definition (i.e. it does not raise capital from a number of investors, with a view to investing it in accordance with a defined investment policy for the benefit of those investors).	Yes, unless it falls outside the AIF definition (i.e. it does not raise capital from a number of investors, with a view to investing it in accordance with a defined investment policy for the benefit of those investors).	Always an AIF.	In principle, no (as it would not be considered as “raising” capital from a number of investors as the structure generally serves for the investment of the private wealth of a “pre-existing group” (as defined in the Esma guidelines on key concepts of the AIFMD)).	No, in case • such vehicle meets the definition of “securitisation special purpose vehicle ” under the AIFM Law; • it issues collateralised debt obligations; • it only issues debt instruments; • such entity is not managed according to an investment policy within the meaning of the AIFM Law.	Non-AIF, unless activities fall within the scope of article 1 (39) of the AIFM Law.	Non-AIF, unless activities fall within the scope of article 1 (39) of the AIFM Law.
Exemption from AIFMD full regime under lighter regime (AIFMD registration regime)	Not applicable.	Possible.	No.	Possible.	Possible.	No.	Not applicable.	Possible.	Possible.	Possible.
External authorised AIFM requirement	Not applicable.	Required in case the entity is an AIF that is not self-managed and above the AIFMD threshold.	Required in case the entity is an AIF that is not self-managed. Always an authorised EU AIFM.	Required in case the entity is an AIF that is not self-managed and above the AIFMD threshold.	Required in case the entity is an AIF that is not self-managed and above the AIFMD threshold.	Always required.	Not applicable.	Required in case the entity is an AIF that is not self-managed and above the AIFMD threshold.	Required in case the entity is an AIF that is not self-managed and above the AIFMD threshold.	Required in case the entity is an AIF that is not self-managed and above the AIFMD threshold.
Eligible investors	Unrestricted.	Unrestricted.	Unrestricted.	Well-informed investors, namely institutional or professional investors (MiFID II), or other investors who confirm their status in writing and either invest at least EUR 100,000 or are assessed by a credit institution, investment firm, UCITS ManCo or authorised AIFM as having sufficient expertise, experience and knowledge.	Well-informed investors, namely institutional or professional investors (MiFID II), or other investors who confirm their status in writing and either invest at least EUR 100,000 or are assessed by a credit institution, investment firm, UCITS ManCo or authorised AIFM as having sufficient expertise, experience and knowledge.	Well-informed investors, namely institutional or professional investors (MiFID II), or other investors who confirm their status in writing and either invest at least EUR 100,000 or are assessed by a credit institution, investment firm, UCITS ManCo or authorised AIFM as having sufficient expertise, experience and knowledge.	Restricted to: • natural persons acting in the context of the management of their personal wealth; • management entities acting solely in the interest of the private wealth (e.g. trusts, private foundations); and intermediaries acting for the account of the above mentioned eligible investors (e.g. bank acting under a fiduciary agreement).	Unrestricted.	Unrestricted.	Unrestricted.
Eligible assets	Restricted to transferable securities admitted or dealt on a regulated market, investment funds, financial derivative instruments, cash and money market instruments that are in compliance with article 41 of the Ucits law and the relevant EU directives and regulations. Please note that the eligibility of the asset must be ascertained on a case-by-case basis in view of the applicable laws and regulatory practice.	Unrestricted. The investment objective and strategy of the fund is subject to the prior approval of the CSSF.	Restricted to: - equity or quasi-equity instruments and debt instruments issued by a qualifying portfolio undertaking; -loans granted by the ELTIF to a qualifying portfolio undertaking with a maturity that does not exceed the life of the ELTIF, - units or shares of one or several other ELTIFs, EuVECAs, EuSEFs, UCITS and EU AIFs managed by EU AIFM provided that those ELTIFs, EuVECAs, EuSEFs¸ UCITS and EU AIFs invest in eligible investments (this wording) and have not themselves invested more than 10% of their assets in any other UCI; - real assets; - certain STS securitisations (where the underlying exposures are residential mortgage-backed securities, commercial loans backed by mortgages on commercial immovable property, credit facilities, trade receivables and other underlying exposures; provided that, for the two last ones, the proceeds from the securitisation bonds are used for financing or refinancing long-term investments), - EU Green Bonds issued by a qualifying portfolio, and UCITS eligible assets. Qualifying portfolio undertaking is an undertaking that fulfils, at the time of the initial investment, the following requirements: - it is not a financial undertaking undertaking, unless it is a financial undertaking, other than a financial holding company or a mixed-activity holding company, that has been authorized or registered more recently than 5 years before the date of the investment (fintechs); - is not admitted to trading on a regulated market or on a multilateral trading facility; or is admitted to trading on a regulated market or on a multilateral trading facility and has a market capitalisation of no more than EUR 1 500 000 000; - it is established in a Member State, or in a third country provided that the third country is not identified as high-risk third and is not mentioned in the EU list of non-cooperative jurisdictions for tax prusposes. ELTIFs are not allowed to: - short sell - take direct or indirect exposure to commodities; - enter into securities lending, securities borrowing, repurchase transactions, or any other agreement which has an equivalent economic effect and poses similar risks, if more than 10 % of the assets of the ELTIF are affected; - use financial derivative instruments, except where the use of such instruments solely serves the purpose of hedging the risks inherent to other investments of the ELTIF.	Unrestricted. The investment objective and strategy of the fund is subject to the prior approval of the CSSF.	Restricted to investments in securities representing risk capital as specified in CSSF Circular 25/901 which has replaced Circular 06/241. The circular clarifies the criteria applied by the CSSF when assessing whether investments pursued by a SICAR qualify as risk capital, notably the intention to develop the target entity, the existence of a specific risk going beyond mere market risk, an exit strategy and, where appropriate, a degree of control or supervision A SICAR may use derivatives for hedging purposes or if such transactions are necessary to the realisation of its investment policy. However, investments in derivatives may not be the object of its investment policy, as they are not used, in principle, to create value in itself or to contribute to the development of the target entity. The investment of a SICAR in real estate is only possible through intermediary vehicles (such as SPVs) or real-estate funds. The underlying real-estate assets must meet the criteria of risk capital set out in CSSF circular 25/901.	Unrestricted, unless the RAIF is established as a SICAR-type RAIF investing exclusively in risk capital.	Restricted to acquisition, detention, management and realisation of financial assets. The SPF is not allowed to carry out commercial activities or to hold directly real estate (except for its own use or through its participations).	Unrestricted. The securitisation vehicle may acquire or assume, directly or through another undertaking, risks relating to claims, other assets, or obligations assumed by third parties or inherent to all or part of the activities of third parties and issues financial instruments or contracts, for all or part of it, any type of loan, whose value or yield depends on such risks.	Unrestricted.	Unrestricted.
Risk diversification requirements	Risk diversification requirements are provided by articles 42 et seq. of the UCITS Law, e.g. (not exhaustive): • a UCITS may not invest more than 10% of its assets in transferable securities or money market instruments issued by the same body; • a UCITS may not invest more than 20% of its net assets in deposits made with the same body; • the global exposure relating to derivative instruments does not exceed the total net value of the UCITS portfolio.	Risk diversification requirements applicable to Part II UCIs are set out in CSSF Circular 25/901, which specifies the concept of risk-spreading referred to in Articles 89(1), 93(1) and 97 of the Law of 17 December 2010. In principle, Part II UCIs marketed to unsophisticated retail investors may not invest more than 25% of their assets or commitments to subscribe in a single issuer, entity or asset, subject to specific derogations. For Part II UCIs reserved to well-informed or professional investors, this limit is raised to 50%, and up to 70% for a single infrastructure investment. The circular allows for duly justified derogations and provides for ramp-up and, where applicable, wind-down periods during which investment limits may not apply, subject to CSSF acceptance.	Risk diversification requirements are provided by articles 13 and 17 of the ELITF Regulation (not exhaustive): ELTIFs marketed to retail investors shall not invest more than: - 20 % of its capital in instruments issued by, or loans granted to, any single qualifying portfolio undertaking; - 20 % of its capital in a single real asset; - 20 % of its capital in units or shares of any single ELTIF, EuVECA, EuSEF, UCITS, or EU AIF managed by an EU AIFM; - 10 % of its capital in UCITS (liquid) assets where those assets have been issued by any single body; or 25 % where bonds are issued by a credit institution which has its registered office in a Member State and is subject by law to special public supervision designed to protect bond-holders; - The aggregate value of STS Securitisations in an ELTIF portfolio shall not exceed 20% of the value of the capital of the ELTIF; - The aggregate risk exposure to a counterparty of the ELTIF stemming from OTC derivative transactions, repurchase agreements, or reverse repurchase agreements shall not exceed 10 % of the value of the capital of the ELTIF.	Risk diversification requirements are set out in CSSF Circular 25/901. For SIFs and compartments thereof reserved for well-informed or professional investors, the following concentration limits apply - a maximum of 50% of assets may be invested in a single issuer, entity, or asset; - a higher limit of up to 70% applies to a single infrastructure investment. The circular also allows a defined ramp-up period and a wind down period up to 4 years for private investments, during which limits may not apply as described in the sales document.	No risk diversification requirements. A SICAR may set investment limits in its sales document and may include ramp up and wind down periods during which those self-imposed limits do not apply.	Aligned with SIF risk diversification rules, unless the RAIF has opted to invest exclusively in risk capital and is therefore subject to the SICAR regime, as stated in its constitutive documents..	No risk diversification requirements.	No risk diversification requirements.	No risk diversification requirements.	No risk diversification requirements.
Legal form	• FCP • SICAV (SA) • SICAF (SA,SCA) All of these entities must be open-ended.	• FCP • SICAV (SA) • SICAF (SA, Sàrl, SCA, SCS, SCSp) The entities may be open-ended or closed-ended.	• FCP, SICAV and SICAF in various legal forms, Soparfis, SCS, SCSp, SCA and future forms entitling an AIF to be authorized as an ELTIF. In principle closed-ended, but may be open-ended provided certain safeguards are set up, inter alia: - redemptions are not granted before the end of a minimum holding period or before the date specified in the rules or instruments of incorporation - at the time of authorisation and throughout the life of the ELTIF, the manager is able to demonstrate that the ELTIF has an appropriate redemption policy and LMTs compatible with the long-term strategy of the ELTIF.	• FCP • SICAV (SA, Sàrl, SCA, SCoSA, SCS, SCSp) • SICAF (SA, Sàrl, SCA, SCoSA, SCS, SCSp) The entities may be open-ended or closed-ended.	• SA • Sàrl • SCA • SCS • SCSp • SCoSA The entities may be open-ended or closed-ended.	• FCP • SICAV (SA, Sàrl, SCA, SCoSA, SCS, SCSp) • SICAF (SA, Sàrl, SCA, SCoSA, SCS, SCSp) The entities may be open-ended or closed-ended.	• SA • Sàrl • SCA • SCSA	A securitisation vehicle may be set up in one of the following forms: • a securitisation company (SA, Sàrl, SCS, SCSp, SENC, SCA, SAS, SCSA); or • a securitisation fund consisting of one or several co-ownerships or one or several fiduciary estates and managed by a management company.	• SCS • SCSp	• SA, Sàrl, SCA • SAS • SCoSA • SCS • SCSp
Umbrella structure	Yes.	Yes.	Yes. Application for authorisation as ELTIF of one or more compartments may be submitted	Yes.	Yes.	Yes.	No.	Yes.	No.	No.
Capital requirements	• FCP: EUR 1,250,000 to be reached no later than 6 months following the authorisation by the CSSF. • Self managed SICAV / SICAF: EUR 300,000 at the date of authorisation and EUR 1,250,000 within 6 months following its authorisation.	• FCP: EUR 1,250,000 to be reached no later than 12 months following the authorisation by the CSSF. • Self managed SICAV / SICAF: EUR 300,000 at the date of authorisation and EUR 1,250,000 within 12 months following its authorisation.	As ELTIF is an EU label, the capital requirements applicable to an ELTIF are the capital requirements applicable to fund, in particular due to the national product law.	EUR 1,250,000 to be reached no later than 24 months following the authorisation by the CSSF.	EUR 1,000,000 to be reached no later than 24 months following the authorisation by the CSSF.	• FCP: EUR 1,250,000 to be reached within 24 months from the entry into force of the management regulations. • SICAV: EUR 1,250,000 to be reached within 24 months from the incorporation of the SICAV.	Depends on the form: • SA / SCA: EUR 30,000 • Sàrl: EUR 12,000 • SCSA: no minimum capital.	If the securitisation vehicle is set up as a company, it depends on the form: • SA / SCA: EUR 30,000 • Sàrl: EUR 12,000 If the securitisation vehicle is set up as a fund, there is no minimum capital requirement.	No minimum capital requirement.	Depends on the form: • SA / SCA: EUR 30,000 • Sàrl: EUR 12,000 No minimum capital requirement for other legal forms.
Required service providers	• Management company in case of an FCP. • Depositary institution. • Administrative agent. • Registrar and Transfer Agent. • Approved statutory auditor.	• Management company in case of an FCP. • Depositary institution. • Administrative agent. • Registrar and Transfer Agent. • Approved statutory auditor. • Registered AIFM or Authorised AIFM in case of an AIF above threshold.	• As ELTIF is an EU label, the required service providers for an ELTIF depend on the applicable national product law. • Management company in case of an FCP. • Depositary bank or professional of the financial sector providing depositary services, subject to conditions. However, if the ELTIF is marketed to retail investors, the Depositary shall comply with the UCITS depositary requirements and be a Depositary institution • Administrative agent. • Registrar and Transfer Agent. • Authorised AIFM. • Other service providers required by the relevant product rules.	• Registered AIFM or authorised AIFM in case of an AIF above threshold. • Management company in case of an FCP. • Depositary bank or professional of the financial sector providing depositary services, subject to conditions. • Administrative agent. • Registrar and Transfer Agent. • Approved statutory auditor.	• Registered AIFM or authorised AIFM in case of AIF above threshold. • Depositary bank or professional of the financial sector providing depositary services, subject to conditions. • Administrative agent. • Registrar and Transfer Agent. • Approved statutory auditor.	• Authorised AIFM. • Management company in case of an FCP • Depositary bank or professional of the financial sector providing depositary services, subject to conditions. • Administrative agent. • Registrar and Transfer Agent. • Approved statutory auditor.	Registered auditor in principle not required unless two of the following criteria are met: (i) net turnover above EUR 8.8 million, (ii) balance sheet above EUR 4.4 million and (iii) average number of employees above 50. However, depending on the legal form of the company, there may be an obligation to appoint a commissaire aux comptes.	• Alternative Investment Fund Manager (if the securitisation vehicle qualifies as an AIF). • Management company (if the securitisation vehicle is set up in the form of a fund). • Independent auditor. • No depository institution (unless for regulated securisation vehicles). • No administrative agent.	For SCS: • Alternative Investment Fund Manager (if the SCS qualifies as an AIF). • No requirement to appoint a depositary (except if the SCS qualifies as an AIF and is managed by a duly authorised AIFM). For SCSp: • Alternative Investment Fund Manager (if the SCSp qualifies as an AIF). • No requirement to appoint a depositary (except if the SCSp qualifies as an AIF and is managed by a duly authorised AIFM).	Registered auditor in principle not required unless the company is an AIF managed by an AIFM with AUM above the threshold or two of the following criteria are met: (i) net turnover above EUR 8.8 million, (ii) balance sheet above EUR 4.4 million and (iii) average number of employees above 50. However, depending on the legal form of the company, there may be an obligation to appoint a commissaire aux comptes. On 28 July 2023, draft bill 8286 (the Draft Bill) was released, aiming to overhaul Luxembourg accounting law applicable to undertakings (the New Law). It is expected to be adopted in 2025.
Possibility of listing	Yes.	Yes.	Yes.	Yes.	Yes, but difficult in practice.	Yes.	No.	No.	In principle, no. The SCS/SCSp may however issue debt securities that are eligible to be listed on the stock exchange.	Yes.
European passport	Yes.	Yes, but needs to fall under the scope of the full AIFMD regime.	Yes.	Yes, but needs to fall under the scope of the full AIFMD regime.	Yes, but needs to fall under the scope of the full AIFMD regime.	Yes (always under the full AIFMD regime).	No.	No, unless it falls under the scope of the full AIFMD regime.	No, unless it falls under the scope of the full AIFMD regime.	No, unless it falls under the scope of the full AIFMD regime.
Net asset value (NAV) calculation and redemption frequency	The UCITS must make public the issue, sale and repurchase price of their units each time they issue, sell and repurchase their units, and at least twice a month.	The UCIs must make public the issue, sale and repurchase price of their units each time they issue, sell and repurchase their units, and at least once a month.	The UCIs must make public the issue, sale and repurchase price of their units each time they issue, sell and repurchase their units, and at least once a month. As ELTIF is an EU label, the NAV computation and redemption frequency depend on applicable national product law and the AIFM law. At least once a year for reporting purposes. Redemption frequency: In principle closed-ended, but may be open-ended provided certain safeguards are set up, inter alia: - redemptions are not granted before the end of a minimum holding period or before the date specified in the rules or instruments of incorporation - at the time of authorisation and throughout the life of the ELTIF, the manager is able to demonstrate that the ELTIF has an appropriate redemption policy and LMTs compatible with the long-term strategy of the ELTIF; - redemptions are limited to a percentage of the UCITS (liquid) assets of the ELTIF. An ELTIF may offer, under certain conditions, early redemption rights to its investors according to the ELTIF's investment strategy.	At least once a year.	The valuation of the assets of the company is based on the "fair value".	At least once a year.	Not required.	Not required.	Not required.	Not required.
Borrowings / leverage limits	Borrowings of up to 10% of net assets to finance redemptions (it should be a short term borrowing and cannot be for investment purposes) or to buy real estate for its business. The total borrowing under the above may not exceed 15% of net assets.	Part II UCI may borrow cash. Where borrowing is used for investment purposes and the fund or compartment is marketed to unsophisticated retail investors, borrowing must, in principle, not exceed 70% of its assets or commitments to subscribe. Where the fund or compartment is reserved to well-informed or professional investors, this limit does not apply and the maximum borrowing level is determined by the fund and disclosed in its sales document.	As ELTIF is an EU label, there is no harmonised EU-level debt-to-equity ratio and any product-specific leverage constraints depend on the national rules applicable to the AIF. Borrowings of cash of up to 50% of the NAV of the ELTIF marketed to retail investors and up to 100% for the ELTIF marketed solely to professional investors.	No debt-to-equity ratio. According to circular 25/901, SIFs may borrow cash for investment and operational purposes. The Fund or compartment may set its own borrowing limits.	No debt-to-equity ratio. CSSF Circular 25/901, limits the use of borrowing in consideration to the specific objective of the SICAR. Reference should be made to the general principles laid down in Chapter 5 of the circular. When borrowing cash, the fund or the compartment may encumber assets.	No debt-to-equity ratio.	Tax of 0.25% on the debt that exceeds 8 times the paid-up capital increased by the issue premium.	No debt-to-equity ratio.	No debt-to-equity ratio.	No provision in Luxembourg law. However, there is a specific administrative practice.
Overall income tax (corporate income tax and municipal business tax)	No income tax.	No income tax.	As ELTIF is an EU label the tax treatment depends on the national product rules applicable to the AIF.	No income tax.	• General aggregate rate: 23.87%. In certain cases, reduced corporate income tax rates may apply. Income derived from transferable securities (e.g. dividends received and capital gains realised on the sale of shares) is exempt. Income on cash held for the purpose of a future investment is also exempt (for one year).	No income tax, unless investing only in risk capital, then SICAR tax regime applicable.	No income tax.	• General aggregate rate for taxable securisation companies: 23.87%. Securitisation vehicles should be able to deduct from their gross profits their operational costs and the dividends or interests distributed to the shareholders/creditors. Therefore securitisation companies should not generate significant taxable profits and should therefore to a large extent be tax neutral.	No corporate income tax applicable. Municipal business tax of 6.75% applicable in very limited circumstances, namely in case the SCS/SCSp (i) carries out a commercial activity or (ii) is deemed to carry out a commercial activity. A SCS/SCSp is deemed to carry out a commercial activity if its general partner is a Luxembourg public or private limited liability company holding at least 5% of the partnership interests. With a proper structuring of the GPs partnership interest it should be possible to avoid the deemed commercial characterisation of the SCS/SCSp.	General aggregate rate: 23.87%, but 100% exemption for dividends, liquidation proceeds and capital gains from qualifying participations.
Subscription tax (NAV: net asset value)	• Rate: 0.05% of the NAV annually. • Reduction: 0.01% of the NAV annually in certain specific cases. • Where the proportion of net assets of a UCITS or one of its compartments in certain Taxonomy-sustainable activities represents at least 5 per cent of the aggregate net assets of the UCITS or of its relevant compartment, the subscription tax rate is 0.04 per cent. Where the proportion of such assets is at least 20 per cent, this rate amounts to 0.03 per cent. Where the proportion is at least 35 %, the subscription tax rate amounts to 0.02 per cent. Where the proportion is at least 50 per cent, this rate amounts to 0.01 per cent. However, net assets in nuclear energy and fossil gaseous fuel are excluded from such decreased rates. • Tax exemptions: special institutional money market cash funds, special pension funds (including pension pooling vehicles) and funds investing in other funds which are already subject to subscription tax.	• Rate: 0.05% of the NAV annually. • Reduction: 0.01% of the NAV annually in certain specific cases. • Where the proportion of net assets of a UCITS or one of its compartments in certain Taxonomy-sustainable activities represents at least 5 per cent of the aggregate net assets of the UCITS or of its relevant compartment, the subscription tax rate is 0.04 per cent. Where the proportion of such assets is at least 20 per cent, this rate amounts to 0.03 per cent. Where the proportion is at least 35 %, the subscription tax rate amounts to 0.02 per cent. Where the proportion is at least 50 per cent, this rate amounts to 0.01 per cent. However, net assets in nuclear energy and fossil gaseous fuel are excluded from such decreased rates. • Tax exemptions: special institutional money market cash funds, special pension funds (including pension pooling vehicles) and funds investing in other funds which are already subject to subscription tax.	As ELTIF is an EU label the tax treatment depends on the national product rules applicable to the AIF.	• Rate: 0.01% of the NAV annually. • Tax exemptions: certain money market and pension funds or SIFs investing in other funds which are already subject to subscription tax.	No subscription tax.	• Rate: 0.01% of the NAV annually. • Exemptions apply.	Annual subscription tax of 0.25% on the amount of paid up capital and issue premium (if any).	No subscription tax.	No subscription tax.	No subscription tax.
Wealth tax	No wealth tax.	No wealth tax.	As ELTIF is an EU label the tax treatment depends on the national product rules applicable to the AIF.	No wealth tax.	No wealth tax.	No wealth tax.	No wealth tax.	No wealth tax.	No wealth tax.	0.5% on a taxable base of up to EUR 500 million. As of 1 January 2025, there is progressive net wealth tax based solely on the company's total balance sheet size, regardless of asset composition: • €535 for companies with a total balance sheet up to and including €350,000 • €1,605 for companies with a total balance sheet between €350,001 and €2,000,000 • €4,815 for companies with a total balance sheet exceeding €2,000,000
Withholding tax on dividends	Not subject to withholding tax.	Not subject to withholding tax.	As ELTIF is an EU label the tax treatment depends on the national product rules applicable to the AIF.	Not subject to withholding tax.	Not subject to withholding tax.	Not subject to withholding tax.	Not subject to withholding tax.	Not subject to withholding tax.	Not subject to withholding tax.	Dividends distributed by a Luxembourg company are in principle subject to withholding tax at a rate of 15%, unless a domestic law exemption or a lower tax treaty rate applies.
Benefit from Double Tax Treaty network	• SICAV/SICAF: Limited to certain double tax treaties (see circular L.G. -A n°61 of the tax administration of 24 December 2024). • FCP: see circular L.G.-A n°61 of the tax administration of 24 December 2024.	• SICAV/SICAF: Limited to certain double tax treaties (see circular L.G. -A n°61 of the tax administration of 24 December 2024). • FCP: see circular L.G.-A n°61 of the tax administration of 24 December 2024.	As ELTIF is an EU label the tax treatment depends on the national product rules applicable to the AIF.	• SICAV/SICAF: Limited to certain double tax treaties (see circular L.G. -A n°61 of the tax administration of 24 December 2024). • FCP: see circular L.G.-A n°61 of the tax administration of 24 December 2024.	Yes in case the SICAR is set-up as a corporate entity (except if set-up under the form of a SCS/SCSp).	• RAIFs investing in a portfolfio of risk capital (such as a SICAR) Access if set-up as a corporate entity (except if set-up under the form of a SCS/SCSp). • RAIFs not investing in a portfolio of risk capital (such as a SICAR), but set-up as: SICAV / SICAF: Limited to certain double tax treaties (see circular L.G. -A n°61 of the tax administration of 8 December 2017). FCP: see circular L.G.-A n°61 of the tax administration of 8 December 2017.	No.	Yes for securitisation companies.	No.	Yes.
Benefit from the EU Parent Subsidiary Directive	No.	No.	As ELTIF is an EU label the tax treatment depends on the national product rules applicable to the AIF.	No.	In principle yes, but certain jurisdictions where the target companies are located may challenge the application of the directive.	No, unless RAIF that invests in a portfolio of risk capital (such as a SICAR).	No.	Yes.	No.	Yes.