Luxembourg: Fund Management/ REITs

Part II UCIs provide North American fund managers with a regulated Luxembourg vehicle to access international private wealth markets through a flexible, company-style fund structure.

In March 2026, we published a client alert1 examining the Commission de Surveillance du Secteur Financier’s (CSSF) updated FAQ on crypto assets in investment funds and the key changes since the initial 2022 guidance.

European institutional investors increasingly favor Article 8 funds under SFDR, which promote environmental and social characteristics alongside good governance practices. US fund managers face strategic decisions when entering the EU market, weighing the benefits of Article 8 classification against operational constraints and investor preferences. The regulatory landscape offers flexibility in ESG implementation, though upcoming SFDR 2.0 reforms will reshape these disclosure requirements by late 2027.

AIFMD II introduces risk retention rules requiring EU authorized alternative investment fund managers to retain at least 5% exposure when transferring originated loans to third parties.

Luxembourg offers a cost-efficient alternative for emerging fund managers through its registered AIFM structure, commonly known as the "small manager" route. This approach allows fund managers to establish Luxembourg AIFs while avoiding the substantial costs associated with authorised host AIFMs, though it comes with specific asset thresholds and marketing limitations.

Wenn die BaFin Immobilien und Immobilienfonds auch im Jahr 2026 erneut als zentrales Fokusrisiko einstuft, spricht vieles dafür, dass sich der bereits laufende Stresstest für alternative Immobilienanlagen fortsetzt.

Following earlier announcements and market consultation, Luxembourg has formally adopted its long‑awaited reform of the carried interest regime.

Eagerly awaited by the Luxembourg asset management industry, the Luxembourg parliament finally adopted bill of law n° 8590 on January 22, 2026 to revamp Luxembourg's carried interest tax regime.

As anticipated in our recent Maples Group update "Recent Amendments to Luxembourg's Proposed New and Improved Carried Interest Tax Regime", Luxembourg has enacted a modernised...