Every tokenized deal leads with a gross number. The pitch deck says 7%, or 12%, or 20%. None of those is the number you keep. Between the headline gross yield and the net-in-pocket figure sits a cascade of haircuts: SPV-level operating costs, corporate tax in the SPV jurisdiction, dividend withholding to your residency, advisor and AIFM fees, audit, depositary, custody. This guide walks that cascade end to end across five EU tokenized real-asset categories in 2026, names every haircut, and shows why net-in-pocket typically lands at 60-75% of the gross headline. The point is not that the deals are bad. The point is that the gross headline is the start of the analysis, never the end.
A gross yield is measured at the asset. It is what the warehouse earns in rent, what the battery earns from the grid, what the loan book earns in interest, before anything is taken out. A net yield is measured in your pocket, after every cost between the asset and you has been paid. The distance between the two is the cascade, and it is the single most underexplained number in tokenized real-asset investing.
This matters because the entire pitch is built on the gross number. A deck that leads with 18% is leading with the most flattering figure available, and there is nothing wrong with that as long as the allocator knows it is gross. The failure mode is the allocator who sizes a position as if 18% is what they will earn, then discovers at the first distribution that the cascade took it to 12%, and the position was sized on an assumption that was 50% too high.
The good news is that the cascade is knowable in advance. Every haircut in it is a published rate or a contractable cost: corporate tax rates are public, treaty withholding rates are public, advisor and fund fees are quotable, audit and custody costs are quotable. An allocator who does the cascade before wiring knows the net figure to within a point or two. An allocator who does not is sizing on hope.
This guide is the cascade, applied to the five categories that make up most accredited EU tokenized real-asset deal flow in 2026. For the full menu of those categories, see the 9 EU tokenized deals guide. For the asset-class-by-asset-class yield framing, see the tokenization vs REITs guide.
The cascade has five layers. Not every deal has every layer (a directly-held SPV skips the AIFM fee; some structures skip custody), but this is the full set, in the order they apply.
Before the SPV earns a profit, it pays the costs of holding and running the asset: property management for real estate, O&M contracts for energy, servicing for credit. These come out at the asset level and turn the gross yield into a net operating yield (the cap rate, in property terms). Typical haircut: 0.5 to 2 percentage points depending on asset class, heaviest for actively-managed assets like NPL workout and lightest for passive operating solar.
The SPV pays corporate tax on its profit in its jurisdiction before distributing anything. This is usually the single largest haircut. Headline rates in 2026: Romania 16%, Austria 23%, Liechtenstein 12.5%, Luxembourg 23.87%, Malta 35% headline (with a refund mechanism that can bring the effective rate to single digits for qualifying structures). A Luxembourg holding structure with the participation exemption can substantially neutralise this layer for qualifying institutional investors.
When the SPV distributes profit to the allocator, withholding tax applies, at a rate set by the tax treaty between the SPV jurisdiction and the allocator's residency. For treaty-resident holders this typically runs 0 to 15%. For non-treaty or domestic holders it can be materially higher, and the 2026 numbers matter: Romania raised its dividend withholding from 10% to 16% effective January 2026, and Austria's domestic rate (27.5%) is treaty-reduced for foreign holders. This is the layer most sensitive to the allocator's own residency, and the one a generic pitch deck cannot model because it does not know who is buying.
Two structural escapes from this layer are worth knowing, because they change the net by a full point or more. First, the EU Parent-Subsidiary Directive zeroes dividend withholding where the holder is a qualifying EU parent company with a 10%-plus stake held for 12 months, which is why energy-infrastructure SPVs are often held through an Estonian, Dutch, or Luxembourg holding company rather than by allocators directly. The catch: individual token-holders usually do not qualify for the directive and face the full domestic rate, so the structuring decision (hold through a qualifying parent, or distribute directly to tokens) directly determines whether Layer 3 costs 0% or 16%. Second, loan-based distribution (a participatory or shareholder loan, the assignment-of-receivables route) routes return to the allocator as interest rather than dividend, which can sit outside the dividend-withholding regime entirely. Where it is correctly structured and the interest is deductible at the SPV level, this can compress both Layer 2 and Layer 3 at once. Both routes are structuring choices an allocator should ask about explicitly, because the cascade above assumes a plain equity distribution and the loan route can look materially different.
The sourcing-and-structuring layer. A direct deal sourced through an advisor may carry a success fee (usually paid by the operator, but worth understanding). An AIFM-wrapped fund carries a management fee of 1-2% of AUM plus a depositary fee of 5-15 basis points. This layer is 0 for a directly-held deal with no advisor carry and 1-2 points for a fund-wrapped position. The full fund-wrapper cost is in the AIFM-wrapped SPV guide; the broader fee picture is in the advisor fees guide.
The tokenization-specific cost. A tokenized structure carries one fee layer a traditional SPV does not: the platform. Token issuance typically costs 1-5% of capital raised as a one-off, plus ongoing listing, registry, and on-chain custody fees thereafter. On a multi-year hold the issuance fee amortises to a fraction of a point per year, but it is real and it is specific to the tokenized wrapper, so it belongs in the cascade for any tokenized deal even though it never appears in a traditional fund's cost stack. The platform-by-platform breakdown is in the platforms comparison guide.
The ongoing-compliance layer. Audit of the SPV financials, depositary oversight (for AIFM-wrapped structures), and custody of the tokens (qualified custody typically 10-50 basis points annually for institutional holders). Smaller than the tax layers but real, and routinely omitted from gross-yield marketing. Typical combined haircut: 0.2 to 0.8 percentage points.
The shape of the cascade: the two tax layers (corporate tax and dividend withholding) do most of the damage, the operating layer is asset-class-specific, and the fee-and-compliance layers are smaller but real. Stack them and net-in-pocket lands at roughly 60-75% of gross across most EU tokenized real-asset categories. The exact figure is allocator-specific because layers 2, 3, and 4 all depend on jurisdiction, residency, and structure.
Take the 3,057 sqm refurbished light-industrial warehouse in St. Pölten on this desk, a real worked example rather than a hypothetical. The headline is a projected 7.7% gross rental yield once the property is let at the listed rent. Here is the cascade.
The corporate-tax line deserves a note, because the headline 23% is applied to taxable profit, not to the gross yield. Twenty-three percent of the ~7.1% operating yield is about 1.6 percentage points before any allowances. But Austrian commercial property carries a depreciation allowance (AfA, roughly 2.5-3% of the building value per year) that reduces the taxable rental profit, so the cash-tax drag in the early years is often below that 1.6 points, while non-deductible costs and Grundsteuer push the other way. The honest landing is a net at company level around 5.1 to 5.5%, not a single precise figure, and an allocator should ask for the specific deal's tax computation rather than apply the headline rate to the yield directly. (Earlier drafts of this guide applied 23% as a flat 2.0-point haircut on the yield, which overstated the tax drag by ignoring depreciation; the corrected figure is above.)
So a 7.7% gross rental headline becomes roughly 5% net rental in the allocator's pocket, landing in a 4-6% band depending on residency and structure. That is the honest number for the income component.
The second source of return. Rental yield is not the whole story for real estate. Capital appreciation on the property is a separate return realised at exit (sale or refinancing), not included in the rental-yield cascade above. A well-located warehouse with 2-3% annual capital growth delivers that on top of the ~5% net rental, for a total return in the 7-8% range over the hold. But if the capital cycle is flat, the allocator earns the ~5% net rental and no more. This is why honest underwriting frames the deal on the net rental yield as the base case and treats capital appreciation as upside, not as a number to fold into the headline. The full warehouse cascade with the acquisition-cost detail is in the industrial property tokenization guide.
The key reframing: a ~5% net rental yield on a tokenized warehouse is competitive with a good REIT on net income, and the reason to hold the tokenized version is direct named-asset exposure plus the capital-growth call option on a specific property, not a yield premium over public markets. The honest net number changes the entire pitch from "higher yield" to "direct exposure at a comparable net yield," which is a more durable thing to sell.
Energy infrastructure works differently, and the difference matters. A stationary battery deal is quoted on a target gross IRR, not a running yield, and the cascade applies to the distributions rather than to a single annual figure. Take a Romanian BESS deal targeting an 18% gross IRR as the worked example.
An 18% gross IRR nets to roughly 9-15% to the allocator after the cascade, with the exact figure depending heavily on residency and structure. Romania's 16% corporate tax is the lightest of the common SPV jurisdictions, which is one reason so much EU energy-infrastructure deal flow is structured there. But the withholding layer changed in 2026: Romania raised its dividend withholding from 10% to 16% effective January 2026, so a deal that netted ~13% for a direct token-holder under the old rate nets closer to ~12% now if the tokens receive dividends directly. The way around it is structural, as covered in section 02: held through a qualifying EU parent under the Parent-Subsidiary Directive the withholding is 0%, and a loan-based distribution can route the return as interest outside the dividend regime entirely. Which of those applies is the difference between the top and bottom of the withholding line above, so it is the first question to ask on any Romanian energy deal.
The IRR is not a cash yield. An 18% gross IRR over a 5-10 year hold does not mean the allocator receives 18% cash every year. It means the deal targets an 18% annualised return that combines operating-phase distributions with residual value at exit. Some BESS structures pay strong quarterly cash during the operating phase; others back-load returns toward the asset's residual or refinancing value. Always ask what the cash-distribution profile is, separately from the IRR, because two deals with the same 18% IRR can have very different cash timing.
And a battery is a depreciating asset, which makes the distinction sharper than it is for a warehouse. A lithium battery loses roughly 2% of capacity a year and may be worth only a modest residual at year 10. So an IRR figure on a BESS deal can quietly bake in a partial return of capital rather than pure return on capital: an investor who puts in 500,000 and receives a 10% annual distribution for ten years has, on undiscounted cash, mostly been handed their own money back, with the headline IRR depending entirely on the residual value at the end. The warehouse does not work this way, because property does not degrade to scrap and usually appreciates. When you compare a property running yield to a battery IRR, you are comparing a number that excludes capital growth to a number that may include capital loss. That asymmetry is exactly why the next section treats the running-yield-versus-IRR comparison as a trap, not a footnote.
The higher gross on BESS versus the warehouse (18% vs 7.7%) is not free money; it is compensation for different risk. The battery carries technology-degradation risk, capacity-market design risk, and energy-price risk that the warehouse does not. The net-to-gross ratio is similar across both (roughly 60-75%); the absolute numbers differ because the gross differs, and the gross differs because the risk differs. The mobile and stationary BESS cascades in detail are in the stationary BESS guide and mobile BESS guide.
The cascade applied across the five categories that make up most accredited EU tokenized real-asset deal flow. Gross and net are 2026 market-observable ranges; net assumes a treaty-resident allocator holding through a reasonably efficient structure. Your own net will vary with residency and structure.
| Category | Quoted as | Gross | Net-in-pocket | Net / gross |
|---|---|---|---|---|
| Light-industrial property | Running yield | ~6-10% | ~4-7% + capital growth | ~65-70% |
| Operating solar PV | Running yield / IRR | ~7-11% | ~5-8% | ~70-75% |
| Stationary BESS | Target IRR | ~14-22% | ~9-15% | ~65-70% |
| Tokenized private credit | Running yield | ~9-15% | ~6-10% | ~65-70% |
| NPL / distressed-debt | Target IRR | ~12-25% | ~7-16% | ~60-65% |
Three patterns from the table.
The net/gross ratio is remarkably stable across categories, clustering at 60-75%. The cascade is a roughly proportional haircut, so the category with the highest gross also tends to deliver the highest net in absolute terms, just with the most cost taken out along the way. NPL has the widest gross-to-net gap because its heavy active-management cost structure adds to the operating-cost layer.
Solar PV has the best net/gross ratio (70-75%) because operating solar is the most passive asset class in the list: low O&M, predictable PPA cash flow, light operating-cost layer. The cascade takes less out of a passive asset than an actively-managed one.
Real estate is the only category where the net yield is genuinely understated by the cascade alone, because the rental-yield cascade excludes capital appreciation. The other four categories are mostly income plays where the cascade captures the full return; real estate has the second source of return at exit that the running-yield cascade does not show.
The net figures above assume a treaty-resident allocator and an efficient structure. Your actual net depends on your tax residency, your holding structure, and the specific deal's jurisdiction. A short call models the precise cascade for your situation, which a generic table cannot.
Book an investment call →The most common analytical error in this space is not mis-estimating the cascade. It is comparing a running yield to an IRR as if they are the same kind of number. They are not, and the error always flatters the IRR.
A running yield is annual cash income as a percentage of capital. A 7% running yield on a warehouse means roughly 7% of your capital arrives as cash each year (before the cascade). It does not include any change in the asset's value.
An IRR is the annualised total return over the whole hold, including both distributions during the hold and the terminal value at exit. An 18% IRR on a BESS deal includes the residual or refinancing value of the asset at the end, not just the cash along the way.
So when a deck puts a 7% running-yield real-estate deal next to an 18% IRR energy deal, the 18% looks 2.5x better, but the comparison is rigged: the 18% includes terminal value the 7% does not, and the 7% real-estate deal has its own terminal value (capital appreciation) that is not in its running-yield figure. Compared properly, with both deals on a total-return basis, the gap narrows substantially.
The rule: before comparing any two yield numbers, identify whether each is a running yield or an IRR. If they are different types, either convert both to total-return IRR or compare the running-yield components and the terminal-value components separately. Never put a running yield and an IRR side by side and conclude the higher number is the better deal. That conclusion is an artifact of the metric, not a fact about the deals.
This is why the five-category table above flags how each category is quoted. Real estate, solar, and credit are mostly running yield; BESS and NPL are mostly IRR. An allocator building a portfolio across categories has to normalise these before the comparison means anything.
Layer 2 of the cascade, corporate tax, varies enough across EU jurisdictions to move the net yield by a couple of points on the same gross. The same deal nets differently depending on where the SPV sits.
| Jurisdiction | Corporate tax | Effect on the cascade |
|---|---|---|
| Estonia | 0% retained / ~22% on distribution | Zero tax on retained profit (uniquely good for reinvesting growth-phase BESS); ~22% only when distributed; no dividend WHT to non-residents since 2025 |
| Liechtenstein | 12.5% | Lowest flat headline in the EEA; lightest corporate-tax layer |
| Romania | 16% | Light CIT, the default for much CEE energy infrastructure; but dividend WHT rose to 16% in Jan 2026 |
| Austria | 23% | Mid; the DACH default for property; depreciation (AfA) reduces the effective drag |
| Luxembourg | 23.87% | High headline (reduced from 24.94% for FY2025/26), but participation exemption can neutralise much of it for qualifying structures |
| Malta | 35% headline | Drops to single-digit effective via the 6/7 refund mechanism; or elect the new 15% flat-rate FITWI (Pillar Two-aligned) introduced in 2025 |
The headline rate is not the whole story, which is the trap. Malta's 35% looks punitive until the refund mechanism brings the effective rate to single digits for qualifying structures (or the new 15% flat-rate FITWI election applies). Luxembourg's 23.87% looks high until the participation exemption neutralises it for qualifying institutional holders. And Estonia's model is different in kind rather than degree: it charges 0% on retained profit and only taxes distributions (at roughly 22%), which means an SPV that reinvests its cash flow during a growth phase pays no corporate tax at all until it distributes. For an asset that compounds reinvested capital, like a BESS operator scaling its fleet, the Estonian deferral can be worth more than a low flat rate. An allocator reading only the headline corporate-tax rate would rank these jurisdictions wrongly. The effective rate after the jurisdiction's own mechanisms, and after how the structure actually distributes, is what flows into the cascade.
On top of corporate tax, the dividend-withholding layer depends on the treaty between the SPV jurisdiction and the allocator's residency, which is why the same SPV nets differently for a German allocator versus a UAE-resident one versus a US-person (who often cannot access these structures at all). The full per-jurisdiction comparison, including the hidden costs that change the answer mid-deal, is in the EU jurisdiction comparison guide.
The whole guide reduces to one discipline: compare deals on net-in-pocket, never on gross headline. The five steps that get you there.
The output of those five steps is the only figure on which two tokenized deals can be honestly compared. It is also, almost always, materially lower than the gross headline both deals led with, which is exactly why doing the cascade before wiring is the difference between sizing a position on a real number and sizing it on a marketing number.
For a first-pass fit against the live deals on this desk, the calculator takes a ticket size and horizon and shows which deals match. For the precise net figure on a specific deal at your residency, the cascade has to be modelled with your actual tax position, which is what an investment call is for. And before any wire, the deal itself goes through the 9-point due diligence checklist, because a clean net yield on a deal that fails on the operator or the exit is still a deal to walk away from.
Bring a deal you are looking at, or your ticket size and tax residency. A 30-minute call walks the full cascade for your specific situation: which metric the deal is quoted in, the effective tax at the SPV level, your withholding, the fee layer, and the honest net-in-pocket figure. No deck, no gross-headline theatre.
The sequence of deductions between a deal's headline gross yield and the net-in-pocket yield you keep: SPV operating costs, SPV-jurisdiction corporate tax, dividend withholding to your residency, advisor and AIFM fees, audit, depositary, and custody. Net typically lands at 60-75% of gross. See section 02.
Because gross is measured at the asset and net in your pocket, with tax and fee layers between. The two tax layers (corporate tax 12.5-35% by jurisdiction, dividend withholding 0-15% by treaty) do most of the damage; fees and compliance add 1-3 points more. See section 02.
The Austrian warehouse example: 7.7% gross rental → ~7.1% cap rate → ~5.1% after Austrian corporate tax → ~4-6% net-in-pocket rental, plus capital appreciation as separate upside at exit. See section 03.
An ~18% gross target IRR nets to ~9-15% after Romanian corporate tax, withholding, and fees. But an IRR is not a cash yield: it includes residual value at exit, so ask for the cash-distribution profile separately. See section 04.
Corporate tax ranges from 12.5% (Liechtenstein) to 35% headline (Malta, single-digit effective via refund). Luxembourg's 23.87% can be neutralised via participation exemption. Use the effective rate, not the headline. Plus withholding varies by your residency treaty. See section 07 and the jurisdiction guide.
Yes, both ways: they add a 1-2% management fee plus depositary costs (lowering net), but a Luxembourg structure can use the participation exemption to neutralise the tax cascade (raising net). The wrapper is usually chosen for operational reasons; model the yield effect separately. See the AIFM-wrapped guide.
Running yield is annual cash income as a percent of capital; IRR is annualised total return including terminal value at exit. Never compare a running yield directly to an IRR, the IRR always looks better because it includes exit value the running yield does not. See section 06.
Five steps: identify the metric (running vs IRR), apply effective SPV corporate tax, apply your withholding, subtract the fee layer, handle capital appreciation separately for real estate. Compare on net-in-pocket only. See section 08.
The calculator gives a first-pass fit of ticket size and horizon against the live deals. For the precise net figure at your residency (the withholding and participation-exemption layers depend on your details), an investment call models it specifically.