Thomas Badri is Marketing and Communication Officer at OmniTrust in Luxembourg. With experience across diverse sectors such as technology, business services, industry, construction and agriculture, he combines creativity and strategy to design effective communication projects and strengthen OmniTrust’s brand image.
New tax regime for carried interest in Luxembourg
September 5, 2025
Carried interest in Luxembourg rules are set to change following the government’s presentation of draft law n°8590 on 24 July 2025. Carried interest is the share of profits that an Alternative Investment Fund (AIF) allocates to its managers once a hurdle rate has been exceeded. The proposed regime aims to modernise tax treatment, strengthen legal certainty, and enhance Luxembourg’s attractiveness for international fund managers and investors.
Key changes to carried interest in Luxembourg: Draft law n°8590
The new regime would broaden the scope of beneficiaries. It would no longer be restricted to employees of management companies or AIF managers, but would also extend to individuals providing services to fund managers, including employees of external providers, independent directors, and non-employee partners.
Two types of carried interest are defined under the draft law. Contractual carried interest, based solely on contractual rights, would be classified as speculative gain and taxed at 25% of the progressive rate, resulting in an effective marginal rate of about 11.45%. Participation-linked carried interest, connected to a direct or indirect stake in the fund, would also be classified as speculative gain but could qualify for a full exemption if the participation is below 10% and held for more than six months. The exemption would cover both capital gains and distributed income, including through transparent structures.
Other important changes include making the preferential regime permanent, removing the rule that investors must first recover contributed capital before carried interest distributions, and allowing deal-by-deal structures. Beneficiaries of the current framework would automatically transition to the new regime. If adopted, the new system would take effect on 1 January 2026.
Why this matters for the fund industry
The reform is significant for Luxembourg’s alternative investment funds sector. It would provide greater clarity for managers and service providers, reduce the effective tax burden, and bring Luxembourg closer in line with international market practices. The reform also signals Luxembourg’s determination to remain a leading European hub for alternative investment funds in a competitive global environment.
Next steps
The draft law is currently under parliamentary review. If passed, it will apply from 2026 and is expected to provide a clearer, more attractive framework for carried interest. For further analysis of draft law n°8590 and its implications, see Omnitrust.
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Christina Tsiarta
Head of Advisory Services on Sustainability, ESG & Climate Change at Kreston ITH, Kreston Global ESG Advisory Group Chair
Stop the clock: ESG credentials still critical to mid-market success in Europe
June 30, 2025
The recent announcement by Kreston Global UK firm, Kreston Reeves, that it is launching new ESG advisory services highlights that strong ESG credentials remain a crucial and relevant service for the mid-market, despite recent deadline delays. The “Stop the Clock” announcement by the EU Commission in April 2025 has given mid-market firms more time to prepare, not a total veto to all obligations, explains Christina Tsiarta, Chair of the Kreston Global ESG Advisory Group.
“While for some organisations there’s a legal requirement to comply, for example in the UK, where the Department for Business and Trade just released the exposure draft of the UK Sustainability Reporting Standards, for others, it’s a matter of strategic importance and a differentiating factor in the marketplace.”
The regulatory and commercial drivers for environmental, social and governance (ESG) action are still critical for the mid-market to get out in front of. From new sustainability disclosure standards to investor and stakeholder pressure, businesses are being asked to show how they are building long-term value beyond financial returns.
Kreston Reeves, a UK member of the Kreston Global network, has launched a dedicated ESG Advisory and Reporting Service in response to this shift — a move that reflects a wider trend across the network.
“As the Chair of the Kreston Global ESG Advisory Group, I’m particularly excited to see a major firm in the network like Kreston Reeves introduce ESG advisory services,” says Christina Tsiarta. “It shows how critical ESG reporting and compliance have become for organisations of all sizes.”
While regulatory momentum continues to build, Christina believes compliance isn’t the only driver.
“Whatever the incentive, undoubtedly managing ESG issues provides an opportunity for organisations, especially mid-market ones, to grow sustainably and achieve long-term resilience.”
Kreston Reeves’ new ESG Advisory and Reporting Service is designed to help organisations embed ESG into strategic and financial planning. It offers support in four key areas:
ESG strategy development and materiality assessments
Regulatory and voluntary ESG reporting
Carbon footprint measurement
Climate action plan development and implementation
“Strong ESG credentials are no longer a nice-to-have — they are essential to long-term success,” says Dan Firmager, ESG Adviser at Kreston Reeves. “Yet many organisations still struggle to understand and apply ESG thinking to day-to-day business decisions. Our service is designed to bridge that gap.”
The firm has partnered with ESG software provider Neoeco to deliver data-driven insights that align with financial reporting and assurance standards.
“Our ESG Advisory and Reporting Service is designed to bridge that gap, helping clients embed ESG into the heart of their operations, reporting and governance frameworks.”
Christina adds: “This is just one example of how Kreston firms are stepping up to support clients in navigating ESG demands. As expectations grow, the ability to offer clear, finance-aligned advice on ESG will become core to the trusted adviser role.”
Attracting international talent: Luxembourg’s expatriate tax regime
Luxembourg’s expatriate tax regime is the latest tool in the country’s strategy to attract top international talent in an increasingly competitive global market for skilled professionals. Strategically located in the heart of Europe and known for the stability of its economic and tax environment, Luxembourg is reinforcing its position with the introduction of a new version of the regime, effective from January 2025.
This measure offers a straightforward and advantageous tax framework for professionals recruited from abroad, while addressing the needs of companies facing a shortage of specific expertise. It is a valuable tool for competitiveness in an increasingly mobile world. Aurore Calvi, Managing Director at Kreston network member OmniTrust in Luxembourg, shares her insight.
1. Who qualifies as an expatriate employee?
An “expatriate employee” refers to an individual hired outside Luxembourg or seconded by a foreign entity to work in Luxembourg. Unlike cross-border workers who commute daily, expatriate employees relocate and become Luxembourg tax residents.
These highly qualified profiles play a crucial role in innovation, technological development, and the competitiveness of companies in key sectors such as finance, engineering, and research.
2. A new attractive tax regime since 2025
Main advantages:
· 50% exemption on annual gross salary, capped at €400,000 (excluding benefits in kind).
· Valid for up to 8 years, ensuring medium-term tax stability.
· Simplified administrative procedure, with no prior approval required; the employer initiates the process.
Eligibility criteria:
To qualify for the expatriate tax regime, several cumulative conditions must be met:
Tax residency: The employee must become a tax resident of Luxembourg upon starting their role.
No recent links to Luxembourg: The individual must not have been a tax resident or employed in Luxembourg during the five years before their arrival.
Geographical distance: The employee must have lived more than 150 kilometres from the Luxembourg border during those five years.
Minimum salary: Annual gross remuneration must be at least €75,000, excluding non-taxable elements.
Work location: At least 75% of working time must be spent in Luxembourg.
Company quota: No more than 30% of a company’s total staff can benefit from the regime.
3. A strategic tool for employers
This regime is a powerful recruitment tool for attracting international talent. It allows companies based in Luxembourg (or operating there) to offer attractive net compensation packages without increasing their overall labour cost. Its simplicity is an additional benefit, especially for multinational groups used to managing complex mobility processes. It also enables them to remain competitive compared to other European jurisdictions.
4. How does Luxembourg compare to its neighbours?
Country
Duration
Main Tax Benefit
Key Conditions
Luxembourg
Up to 8 years
50% exemption on gross salary (max €400,000)
Foreign hire, must become tax resident, lived >150km away
France
Up to 8 years
Partial exemption on expatriation-related income
Not tax resident in France during the prior 5 years
Belgium
5 + 3 years
30% exemption via specific allowance
No residency or activity in Belgium in the past 5 years
Netherlands
Up to 5 years
Decreasing exemption on part of salary (30%, 20%, 10%)
Recruited from abroad
Luxembourg stands out with a clear, generous, and easy-to-apply regime: no complex calculations, no hidden thresholds—just a transparent and straightforward exemption.
5. A balanced but controlled regime
No prior approval is required, but Luxembourg’s Direct Tax Administration (ACD) may conduct audits afterwards. Employers must therefore retain all supporting documents for the full duration of the regime.
Employees already working in Luxembourg before 2025 can opt into the new regime, but this choice is irrevocable and should be considered carefully, ideally with professional tax advice.
6. Why move to Luxembourg?
Beyond the tax advantages, Luxembourg offers a highly favourable environment for international professionals. Located at the crossroads of Belgium, France, and Germany, it serves as a strategic base for international companies operating across European markets.
The country offers a safe, multilingual, and cosmopolitan living environment, with a workforce representing over 170 nationalities. Modern infrastructure, including international schools, facilitates family relocation. Labour laws are transparent and stable, providing reassurance to both employers and employees.
Combined with its strong economy, proximity to European institutions, and vibrant financial and tech sectors, Luxembourg presents a compelling case. The expatriate tax regime is one of several incentives, making it a highly competitive and welcoming destination.
7. Conclusion
Through this new regime, Luxembourg reinforces its role as a European hub for international talent. By combining tax incentives, administrative simplicity, and a clear legal framework, the modernised system meets the needs of companies facing growing challenges in attracting highly skilled professionals.
It forms part of a broader strategy to encourage the long-term settlement of strategic profiles and support international business development.
For companies or professionals interested in relocating to or doing business in Luxembourg or applying the expatriate tax regime, Kreston can facilitate contact with a local advisor who can assess individual situations and provide tailored guidance throughout the process.
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Dr Manuel Vogel
CEO, Kreston A&O, Switzerland
Dr Manuel Vogel is an accomplished finance executive with extensive experience in international tax (in particular international VAT), corporate governance, and financial management. He acts as interim manager (e.g. currently the Chief Financial Officer at DentaCore AG), and is often asked to serve on the Board of Directors as a finance and tax specialist.
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Kreston Reeves advise Hydraflex on European acquisition
April 11, 2025
Kreston Reeves has carried out tax due diligence and advised the manufacturing business Hydraflex on its acquisition of Hydralectric International and its European subsidiaries in France and Slovenia.
Established in 1989, Hydraflex is a world leading manufacturer of high-quality speciality metal and braided hoses used across a wide range of building and manufacturing processes.
Hydralectric makes bespoke hoses and high-performance valves for the water industry. The acquisition will see both companies expand their manufacturing and distribution capabilities across Europe.
Kreston Reeves advised Hydraflex on the tax due diligence for the acquisition, working alongside Kreston Global member firm Groupe Conseil Union in France and the Slovenian accountants Simič & partnerji d.o.o.
Andrew Griggs said: “Mohammad and I are delighted to have worked alongside Hydraflex and colleagues in France and Slovenia on this deal. We are seeing an increase in cross-border corporate finance transactions, and as part of the Kreston Global network we are well-placed to work with businesses wherever they may be located.”
Duncan MacBain, CEO and founder of Hydraflex said: “This is an important acquisition for Hydraflex and Hydralectric International, significantly building our international reach.
“We are grateful to the teams at Kreston Reeves for the first-class support Andrew, Mohammed and their colleagues provided in the UK and through their partner firms in France and Slovenia. Their advice was on-point, ensuring the deal progressed quickly and efficiently.”
Interpreneur data conducted by Kreston seems to show a weakening resolve in Europe to prioritise ESG in business operations. But this data does not tell the full story. Kreston Global is finding that while clients are juggling a lot of issues, ESG is still gaining momentum.
Shifting priorities, not abandonment
As growth in the global economy begins to decline, clients have a lot of issues to grapple with, issues that they may not have even considered four years ago. But European clients are not pulling back from ESG.
‘In 2023 and into early 2024, sustainable funds in Europe experienced strong inflows, outpacing those in the United States, where ESG investing has become more politicised and faced withdrawals,’ said Carmen Cojocaru, Managing Partner at Kreston Romania. ‘Europe remains a front-runner in adopting sustainable funds, with substantial investment increases, including nearly USD 11 billion in new assets for the first quarter of 2024 alone, more than doubling previous quarter inflows. This suggests not a reduction, but growing enthusiasm and development in ESG. It seems the reported weakening may be more reflective of regional differences, rather than a true decline in Europe.’
ESG in Europe is enduring momentum
ESG adoption has suffered in the US, where it is seen as an issue that has become too politicised and too controversial, but Europe seems to be sidestepping this problem. While ESG issues have always been used in political agendas, in the EU, ESG is not seen solely as a political issue or as a topic with political connotations. If anything, EU discussion surrounding ESG centers around legal and licensing requirements, value chain requests or stakeholder pressures.
‘For example, if the company is large and within the scope of relevant legislation, then for them ESG is a legal requirement,’ said Christina Tsiarta, Head of Advisory Services on Sustainability, ESG & Climate Change at Kreston ITH, and Kreston Global ESG Advisory Group Chair. ‘If the company is an SME, it’s seen as an area that needs to be tackled because of other drivers. In our experience, clients are increasingly understanding how important ESG issues are to manage as an organisation, and taking more and more relevant action beyond just legal compliance.’
Regulatory shifts and investment trends
There has been some noise that increased EU regulation around areas such as data security is forcing ESG further down the list of priorities but Cojocaru and Tsiarta agree that data security and ESG are complimentary to each other.
‘While stricter EU regulations such as GDPR have elevated the importance of data security, they do not overshadow the significance of ESG,’ said Cojocaru. ‘These regulations highlight the need for secure and transparent operations, affecting the scrutiny of ESG-related data. Both issues are equally essential and should be addressed in tandem.’
Why ESG in Europe is still a business priority
Some of the buzz surrounding the topic of ESG might have died down, which could, Tsiarta said, be perceived as softening in the market, but ESG is definitely here to stay. Banks in the EU are now requiring information on ESG to issue certificates of performance for clients, which influence their lending and investment decisions and the terms of engagement. Investors are increasingly requesting information on the ESG performance of companies for their decision-making. Legislation such as the CSRD has expanded the scope of companies that need to report and has introduced a requirement for third-party assurance of reporting. SMEs and SMPs are already facing ESG requests from their value chain and they are in scope of some existing and of upcoming ESG-related legislation.
How ESG is shaping business decisions
All in all, reports of the death of ESG have been greatly exaggerated. ‘Accountancy firms that have invested heavily in meeting client demand on ESG actually need to be expanding their ESG strategy,’ said Tsiarta. ‘There are many drivers pushing companies to improve their performance on ESG, and new business lines are now opening up for accountancy firms as a result.’
The quiet evolution of ESG in Europe
As well as new revenue streams opening up, AI is busy making the traditional offerings obsolete. ESG is one of the main areas of upskilling that companies need to invest in.
Cojocaru is finding that in Europe, companies are doubling down on ESG by investing in industry professionals, especially within accounting firms. ‘Accountancy firms, in particular, stand to benefit from reinforcing ESG principles as they align operations with rigorous standards like the EU’s Taxonomy and the Sustainable Finance Disclosure Regulation,’ she said. ‘This strategic focus not only adheres to regulatory frameworks but also responds to the significant investor demand for sustainable investments.’
ESG pressures persist
While the headlines may have indicated that US firms are running for the hills when it comes to ESG, Chuka Umunna, JPMorgan’s global head of sustainable solutions, told the Reuters Energy Transition conference in London recently that US firms are still moving money in a way that is similar to European ones. The pressure to meet exacting ESG standards is a long way from being eased.
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Kreston UK Academies Benchmark Report 2025
February 18, 2025
Financial strain on academy trusts reaches critical level
The latest Kreston UK Academies Benchmark Report 2025 reveals a worsening financial outlook for academy trusts, with cost pressures continuing to outpace income for a second consecutive year.
The percentage of trusts reporting in-year financial deficits has tripled since 2021, rising from under 20% in 2020/21 to nearly 60% in 2023/24. This means around three in five academy trusts—responsible for more than 10,000 schools across England—are struggling to balance their budgets.
One of the biggest financial challenges facing trusts is the rising cost of teaching and support staff, cited by 81% of respondents. A key issue is that government funding for teachers’ pay has failed to keep pace with increasing costs. Demand for special educational needs and disabilities (SEND) provision is also adding to the financial strain, with significant budget deficits making it harder to provide essential support.
Smaller trusts are particularly vulnerable. In single academy trusts, staff costs have exceeded 75% of revenue income for the first time since 2022, impacting both primary and secondary schools.
Kevin Connor, head of academies at Bishop Fleming, warns that many trusts are heading towards a financial cliff edge. “Rising costs, including national insurance, teacher pay increases, and minimum wage adjustments, are not being fully covered by government funding. The number of pupils with Education, Health and Care Plans (EHCPs) has grown, but many trusts have had to absorb these costs themselves. Without urgent action, this could become an unsustainable financial burden on the sector.”
Diminishing reserves
Financial reserves, which act as a safety net for trusts, are rapidly depleting. More trusts have been forced to dip into their reserves, with 31% now holding less than 5% of income in reserves—a threshold considered a sign of financial vulnerability by the Education and Skills Funding Agency. This figure has increased from 17% in 2022.
While multi-academy trusts (MATs) have, on average, maintained surpluses, these have declined sharply. Smaller trusts saw average surpluses fall from £203,000 in 2022 to just £1,000 in 2023/24. Larger MATs reported an average surplus of £99,000, compared to £1.56 million the previous year. The report reveals an overall net deficit of £8 million in free reserves across trusts for 2023/24.
David Butler, executive author of the report and partner at Bishop Fleming, says this trend is concerning. “Trust reserves are heading in the wrong direction. With cost pressures continuing to mount, there’s a real risk that smaller trusts could run out of money entirely.”
Nick Cross, CEO of King’s Group Academies, adds, “Reserves should be used for unexpected emergencies or investment in improving education. But too many trusts are having to rely on them just to keep schools running, which is not sustainable.”
Growth plans put on hold
Financial constraints are also limiting the expansion of trusts. The removal of the Trust Capacity Fund, which provided financial support for trusts taking on additional schools, has slowed growth, with more than half of trusts expecting to scale back expansion in 2024/25.
Size plays a key role in financial resilience, with over 60% of large MATs confident in their financial stability, compared to less than 50% of smaller trusts.
David Butler notes, “Rising costs and political uncertainty have put the brakes on growth in the sector. Larger trusts tend to be in a stronger financial position due to economies of scale. Many trusts are now weighing the financial risks before deciding whether to expand.”
Hannah Dell, chief operating officer at Gloucestershire Learning Alliance, says financial challenges are making it harder for trusts to take on new schools. “Many schools looking to join a trust are already facing deficits. We’ve had to reassess our growth strategy to ensure new schools are financially viable before they join us.”
Lack of investment impacting school facilities
Funding constraints are also making it harder for trusts to invest in school buildings and infrastructure. To maximise funding from the Condition Improvement Fund (CIF), trusts must contribute 30% of project costs—something that is increasingly difficult with shrinking reserves.
Many trusts are now diverting funds from already limited reserves to cover essential maintenance and repairs. This issue is particularly acute for single academy trusts, where capital income has fallen by 90% to less than £50 per pupil since 2022.
Kevin Connor highlights the challenge this presents. “There’s simply no financial flexibility to invest in major capital projects such as refurbishing classrooms or upgrading facilities.”
Signs of resilience
Despite the financial strain, the report highlights some areas of resilience within the sector. Some trusts have successfully increased investment income by securing more favourable banking interest rates, with a few generating over £1 million in additional revenue in 2023/24.
Energy costs have also become less of a concern, with only 12% of trusts listing heating and electricity as a top financial pressure. This is due to falling energy prices and ongoing efforts to reduce carbon footprints.
Other key findings from the report include:
Per-pupil costs increased by around 8% in 2023/24, down from 16% in 2022/23, indicating that inflation in the academy trust sector remains higher than in the wider economy.
The average size of a multi-academy trust has grown, with the number of schools per MAT increasing by 11.4% year-on-year to just under 12.
Governance structures are strengthening, with all MATs overseeing more than 7,500 pupils now employing governance professionals or equivalent roles, up from 94% in 2022/23.
CEO salaries across medium and large MATs increased by 6% in 2024 after stagnating at around 2% in the previous year.
Progress towards net zero continues, with carbon emissions per pupil reducing by an average of 13% in 2024 compared to the previous year. Further reductions could be achieved with additional financial support.
The Kreston UK Academies Benchmark Report is an annual financial survey of 260 academy trusts, representing almost 2,300 schools across England.
To download the full Kreston Academies Benchmark Report 2025, click here.
Erika is the CEO of Swedish accounting firm, Finhammars, and a qualified CPA with a background in team sports and travel, with a strong professional passion for cooperation and teamwork. Erika is goal-oriented and solution-focused, excelling in progressing, particularly in English-speaking environments. Erika’s expertise includes working with owner-managed companies, addressing auditing, tax matters, K10’s, 3:12 rules, dividends, and group structures, with a focus on future planning.
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