Ireland: a centre of excellence for private assets

Industry landscape

The Irish asset management industry has experienced remarkable growth, reflecting the growing demand for regulated products and the country’s attractive investment environment. As of November 2024, Ireland was home to 8,899 regulated investment funds, with €5 trillion¹ in net assets — a 22% increase from 2023. This surge underscores the Irish market’s appeal for regulated vehicles like the Irish Collective Asset-Management Vehicle (ICAV) and Investment Limited Partnership (ILP). Concurrently, unregulated Irish Special Purpose Vehicles (SPVs) held over €1.1 trillion² in assets, accounting for more than 25% of the European market³.

Recent trends and developments

According to PwC’s Asset and Wealth Management Revolution 2024 Report, the global alternatives industry is forecast to reach $24.6 trillion by 2028⁴. Investors are increasingly diversifying their portfolios, driving demand for asset classes such as infrastructure, digital assets and energy transition investments, alongside traditional private equity and debt offerings. Ireland has firmly established itself as a location of choice for alternative asset managers and investors alike, representing 19.7% of all European fund assets⁵ and attracting 17 of the top 20 global asset managers.

Regulatory and industry developments

Funds Sector 2030: Sectoral Review

Recognising the pivotal role of asset management and fund servicing in Ireland’s private asset sector, the Irish Department of Finance conducted the Funds Sector 2030 Review. This comprehensive review aimed to ensure the industry remains resilient, future-proofed and a benchmark for international best practices. From a private assets perspective, the review recommended implementing measures to enhance the attractiveness of Ireland’s existing authorised fund structures, demonstrating the government’s commitment to the Irish funds sector.

Technology and innovation

Technology is transforming the asset management industry, revolutionising the way investments are traded, securities are held and contracts are settled. This disruption challenges traditional infrastructure and necessitates adaptation by industry players and regulators. Ireland is well-positioned to be a leading innovator in the global asset management industry by leveraging its status as a top fund domicile and a European hub for major technology companies. The convergence of these two sectors presents a unique opportunity for Ireland to capitalise on digital transformation and innovation.

Retailisation of alternatives

As private and retail investors increasingly shift their focus toward alternative investments, increased complexities arise. To unlock this market segment and meet the growing appetite for evergreen structures, asset managers must reinvent their business models and product offerings. Ireland’s long history in the retail-focused ETF market, coupled with its tax certainty throughout the investment lifecycle and robust regulatory landscape, make it an ideal destination for meeting the demands of retail investors.

Irish product offerings

While the ICAV and Section 110 company remain the most popular Irish regulated and unregulated structures, the broader Irish product suite has continued to develop and expand to meet the changing needs of the industry. Recent tax reforms have enhanced Ireland’s investor offering as outlined below.

Investment Limited Partnership (ILP)

Amendments to the legal and regulatory framework governing Ireland’s regulated partnership offering have significantly enhanced its appeal for asset managers seeking to establish an onshore private fund. As an AIFMD-compliant and EU-domiciled common law partnership, the ILP has become Ireland’s flagship partnership vehicle for closed-ended strategies in real estate, private equity, credit, infrastructure and sustainable finance.

Irish holding company regime

The introduction of a participation exemption for foreign dividends from 1 January 2025 enhances Ireland’s competitiveness as a product domicile and improves the holding company structure. These changes, introduced after extensive stakeholder consultation, form part of a broader modernisation and simplification of Ireland’s corporate tax code.

European Long-Term Investment Funds (ELTIF)

The growth of the European and Irish alternatives market has been strengthened by the introduction of the revised regulatory framework for ELTIFs (commonly referred to as ‘ELTIF 2.0’) in 2024. ELTIF 2.0 is proving to be an attractive product for fund promoters and aligns with the EU’s policy priorities of channelling capital toward European long-term investments in the real economy. Furthermore, in the context of the ESG agenda, the long-term nature of ELTIFs complements the return profile of large-scale infrastructure products required for the transition to a greener economy.

Irish ELTIFs offer flexibility, allowing for their establishment as umbrella Qualifying Investor Alternative Investment Funds (QIAIFs) or Retail Investor Alternative Investor Funds (RIAIFs). They can be structured using various legal forms, including the ICAV, Plc, unit trust, Common Contractual Fund (CCF) or ILP. Asset managers can also leverage their current Irish AIF infrastructure by adding an ELTIF sub-fund to existing umbrellas. Enhancing Ireland’s appeal, most Irish ELTIFs benefit from the Irish Central Bank’s 24-hour fast-track authorisation process, enabling rapid speed-to-market and minimising regulatory hurdles.

Alternative Investment Fund Managers Directive (AIFMD) II

AIFMD II amends Directive 2011/61/EU. All EU member states, including Ireland, have until April 2026 to transpose AIFMD II into domestic law. Ireland’s existing regulatory framework for Irish funds engaging in loan origination (other than those governed by the ELTIF regime) will soon be replaced by the implementation of AIFMD II. As Ireland’s current regime is broadly aligned with AIFMD II requirements, its implementation is not expected to result in significant disruption for the Irish funds industry, in contrast to other European asset management hubs that may face more stringent rules.

Ireland’s stable tax regime

The certainty and stability of Ireland’s tax regime has been, and continues to be, a key growth driver for the country’s asset management industry. The national implementation of the global minimum tax rate and the recent public consultation on interest deductibility signal an ongoing commitment to simplification and tax certainty, further enhancing Ireland’s appeal in an asset management context.

Pillar Two 

The implementation of the global minimum tax rate under Pillar Two will fundamentally change the international tax landscape. Irish policymakers have committed to preserving the tax neutrality of Irish funds and securitisation vehicles, introducing rules in a business-friendly manner. Specifically, an exemption from any Pillar Two tax directly on investment funds and specific rules for the treatment of securitisation vehicles have been introduced. These exemptions provide asset managers with the ability to offer investors certainty regarding potential material tax charges while simplifying compliance obligations.

Irish interest regime

The release of a public consultation on the tax treatment of interest in October last year was a welcome announcement for the private assets industry, demonstrating the Irish Government’s commitment to reducing administrative burdens and simplifying the Irish tax regime.

Looking ahead

Ireland has firmly positioned itself as a premier location for private assets, driven by its access to the EU market, regulatory and tax landscape, and an extensive ecosystem of service providers. The introduction of ELTIF 2.0 has further strengthened Ireland’s position as a centre of excellence for investor funds, while the upcoming AIFMD II reform will align Ireland’s loan origination framework with other EU jurisdictions.

To keep pace with the ever-changing dynamics of the global alternatives sector, it is imperative that Ireland’s product suite remains competitive. The enhancements to the regulated Irish limited partnership structure and the reform of the Irish holding company regime through the introduction of a participation exemption have been extremely positive developments for the sector. However, recent macroeconomic developments, technological disruption and the shift towards sustainable finance require continuous evolution to meet the needs of an ever-changing market.

By offering a compelling combination of regulatory excellence, tax efficiency and innovative product offerings, Ireland stands poised to solidify its position as a global leader in the private assets industry.

_Sources

_{1. Irish Funds Industry Association (2025). Total Irish Domiciled Funds (Accessed: 4 April 2025).}

_{2. Irish Funds Industry Association (2023). Irish SPV Report — Q3 2023 (Accessed: 4 April 2025).}

_{3. Irish Debt Securities Association (2025). Why Ireland for SPVs (Accessed: 4 April 2025).}

_{4. PwC (2024). Asset and Wealth Management Revolution: Unleashing the Transformative Power of Disruptive Technology (Accessed: 4 April 2025).}

_{5. Irish Funds Industry Association (2024). Why Ireland 2024 (Accessed: 4 April 2025).}