Interpreting the ‘look-through’ for intermediary entities for Eltifs

Esma and the European Commission have clarified how Eltif managers must apply the “look-through” principle when investing via intermediary vehicles, settling cross-border divergences and endorsing Luxembourg’s supervisory approach. The clarification provides significant comfort to Eltif managers active in private equity, infrastructure, real assets, and private credit, where multi-layered holding structures and aggregator vehicles are common, according to Sebastiaan Hooghiemstra and Gabriël Storm of Loyens & Loeff.