Columbia Threadneedle Investments is preparing to launch a new range of Irish-domiciled active ETFs, but unlike many of its peers, the firm will oversee these funds from Luxembourg, not Dublin. The firm’s Luxembourg management company will act as management company for the ETFs, passporting its services into Ireland, according to Jill Griffin, who leads Columbia Threadneedle’s Luxembourg operations.
“We are very much focused on our core activities, which are classical, as you say, ‘Super Manco’ activities. That’s what we do. That’s our niche here,” Griffin said in an interview with Investment Officer Luxembourg. “The intent, again, is for Columbia Threadneedle Luxembourg to be a part of that ambition, and that we will be the management company, and we’ll be passporting the management company permissions into Ireland for that.”
A ‘Super Manco’ is a management company that holds both a Ucits retail fund license, as well as a AIFMD license for alternative investment funds. Luxembourg is home to several dozen such firms, out of a total of approximately 230 ordinary management companies serving international asset managers.
Luxembourg ManCos working across borders
Columbia Threadneedle’s move confirms a notable shift in how asset managers structure their cross-border operations within the EU’s single market. In the European fund industry, a growing number of asset managers are leveraging Luxembourg-based ManCos to oversee Irish-domiciled funds, including ETFs and alternative investment vehicles.
This cross-border setup is made possible under EU fund passporting rules, which allow authorised ManCos in one EU country to manage funds domiciled in another. Firms such as AXA IM, DWS, Fidelity International, JP Morgan AM, and BNP Paribas AM have all used Luxembourg as a central governance and risk oversight platform while distributing funds across Europe. While Amundi has in recent years shifted ETF governance to Ireland following its acquisition of Lyxor, others continue to rely on Luxembourg’s Super Manco model to consolidate operational expertise and avoid duplicative infrastructure.
CBI permission required
Crucially, this arrangement requires notification and approval from the Central Bank of Ireland (CBI), which acts as the competent authority for Irish-domiciled funds. The Luxembourg Manco must passport its management permissions into Ireland, detailing its oversight functions, delegation framework, and regulatory substance. Once approved, the non-Irish Manco can act as the official Ucits ManCo or AIFM for the Irish fund, enabling a unified governance model while still benefiting from Ireland’s robust fund infrastructure, particularly for ETFs.
Columbia Threadneedle’s upcoming launch of Irish-domiciled active ETFs under Luxembourg management is a textbook example of this approach, combining Luxembourg’s governance strengths with Ireland’s listing advantages.
“It clearly sounds like a good opportunity indeed to keep your own efficiency and at the same time, use the additional benefits that active ETFs in Ireland have,” Griffin said.
“We are domicile-agnostic. We want to go for the best domicile possible for the product and for the benefit of our clients.”
Because of a withholding tax treaty between the US and Ireland, Dublin in recent years has gained increasing prominence as a European hub for ETFs invested in US equities. The treaty stipulates that dividends paid on US equity investments are only taxed at 15 percent, against a rate of 30 percent in Luxembourg and other EU countries.
Columbia Threadneedle’s approach reflects a broader principle of regulatory and operational flexibility under the Ucits directive and AIFMD regime.
“We are domicile-agnostic,” said Griffin. “We want to go for the best domicile possible for the product and for the benefit of our clients. At the same time, we want to make sure that we’ve got the best possible oversight and servicing from a management company perspective. And that’s exactly what we’re doing here.”
Griffin noted that the firm had already fast-forwarded its Manco permissions to oversee an Irish Ucits fund that had previously been managed by a third-party firm.
Building on US platform
The active ETF launch, expected later this year pending regulatory approval, builds on a successful US platform.
“We’re hoping for regulatory permissions and everything to be in place at the end of this year,” said Griffin. “We’ve already got a successful range in the US. So, you know, this is based on this range. It’s not a new territory for us as a global business, but it is new for us here in EMEA.”
Luxembourg structure refreshed
Columbia Threadneedle’s choice to centralise governance in Luxembourg follows a broader strategy that saw the company merge legacy Bank of Montreal Asset Management and Columbia Threadneedle platforms across Europe into its Luxembourg Manco. As of January 2025, all its activities are now grouped under Threadneedle Management Luxembourg SA.
Griffin, who joined the firm in 2023, said the change of the firm’s Luxembourg structure was part of “our broader project to harmonise and eliminate duplication across our EU footprint.”
The firm now oversees funds domiciled in Luxembourg and Ireland from its new offices based next to the Luxembourg airport, with branches across seven European countries.
“We’ve tripled that AUM in terms of aggregating everything in Luxembourg,” Griffin said. “That’s bringing in those third-party ones, that’s bringing in the one with the AIFM that we had in the Netherlands, and also passporting our permission from Luxembourg into Ireland.”
For Griffin, who joined the firm in 2023, this structure offers both efficiency and strategic clarity.
“You don’t want to duplicate. Duplication brings cost,” she said. “You want to make sure that we’ve got our centre of excellence, in this case Luxembourg, there to support whatever the EU activities are.”
The firm’s European assets under management stood at about 60 billion euro per end of March, on a global total of some 575 billion, of which 56 percent is held for retail clients.