Carry and the election
Carried interest sits under the lucrative-interest rules: by default it taxes as income at progressive rates. The established route holds the carry entitlement through the personal holding and elects the box-2 treatment — carry then lands in the structure and taxes at 24.5% within the band on distribution, on your timing, conditions met and papered at fund closing. The election is a closing-checklist item; retrofitting it later is the expensive version: the wider PE architecture.
Co-invest and the pooling layer
GP commitments and co-investments route through the same holding: qualifying stakes pool dividends and exit gains exempt from 5%, and fund-by-fund entities keep vintages clean beneath it. The distribution rhythm harvests the 24.5% band yearly: the liquidity playbook.
The base years, funded properly
Between closings and carry events, the manager is a director-shareholder (DGA) like any founder: the €58,000 benchmark with a lower salary agreed in writing with the tax administration in the build years, private liquidity via borrowing up to €500,000 from the own BV — together typically keeping €18,000–€20,000 per year invested beside the fund: the combination. Management-company regulation has its own map where third-party money enters: the licence overview.