Government draft of 24 July 2025 (amending Art. 99bis LIR, intended from 2026)

What is carried interest?

It is the performance-based share of profits received by beneficiaries.

Current vs. proposed taxation

Aspect	Current	Proposed (24 Jul 2025)
Contractual carry (no investment interest)	Treated as miscellaneous income, taxed progressively; the quarter-rate applied only temporarily to impatriates.	Permanent quarter-rate taxation as extraordinary income; impatriate regime repealed.
Investment-linked carry	Tax-free after 6 months (except > 10% in opaque AIF → half rate).	Largely unchanged; clarification on economic ownership concept.
Distribution condition	Carry payable only after full capital repayment.	This rule may be removed, so deal-by-deal carry could qualify.

What should you do?

• Review structure and documentation in order to distinguish between contractual and investment-linked carry.
• Check eligibility and timing ahead of 2026.

Contact us to assess if and how you could benefit from the new regime.

Please do not hesitate to contact us if you have any questions.

Status: Oktober 31, 2025