Tax Information

6 Months Ended

Jun. 30, 2026

Note 11. Tax Information

The Fund elected to be regulated as a BDC under the 1940 Act on December 19, 2025. In addition, the Fund has elected to be treated as a RIC under Subchapter M of the Code. The Fund intends to qualify each taxable year hereafter as a RIC under Subchapter M of the Code, beginning with its fiscal year ending December 31, 2026. Income or loss earned by the Fund prior to the period in which it elected to be treated as a RIC is not attributable to the shareholders of the RIC.

Prior to the period in which the Fund elected to be treated as a RIC, Partners Group Lending Fund, LLC was classified as an association taxable as a Corporation for U.S. federal tax purposes. Partners Group BDC Finance I, LLC and Partners Group Revolver Pooling BDC, LLC are treated as disregarded entities and, as such, all activities at these entities shall be reported and taxed on Partners Group Lending Fund, LLC’s U.S. federal tax return. For the tax year ended December 31, 2025, in accordance with U.S. federal tax laws, Partners Group Lending Fund, LLC’s taxable income is subject to federal taxes at a 21% rate and state taxes at a 0% rate.

ASC Topic 740, “Accounting for Uncertainty in Income Taxes” (“ASC 740”) provides guidance on the accounting for and disclosure of uncertainty in tax position. ASC 740 requires the evaluation of tax positions taken or expected to be taken in the course of preparing the Fund’s tax returns to determine whether the tax positions are “more-likely-than-not” of being sustained by the applicable tax authority. Tax positions deemed to meet the more-likely-than-not threshold are recorded as a tax benefit or expense in the current year. Based on its analysis of its tax position for all open tax years (the current and prior years, as applicable), the Adviser has concluded that the Fund does not have any uncertain tax positions that met the recognition or measurement criteria of ASC 740. Such open tax years remain subject to examination and adjustment by tax authorities.

As of June 30, 2026, and the year ended December 31, 2025, for U.S. federal income tax purposes, the Fund’s aggregate unrealized appreciation and depreciation on its investments based on cost was as follows:

Schedule of unrealized appreciation and depreciation on its investments
	June 30, 2026			December 31, 2025
Tax Cost	$	525,753		$	456,637
Gross unrealized appreciation		713			2,886
Gross unrealized depreciation		(5,895	)		(1,177	)
Net unrealized investment appreciation	$	(5,182	)	$	1,709

The tax cost of the Fund’s investments as of December 31, 2025, approximates their amortized cost. The tax cost of the Fund's investments as of June 30, 2026 is inclusive of the step-up in basis due to the deemed sale election made by the Fund in conjunction with its intent to elect to be treated as a RIC under the Code.

The Fund’s income tax provision consists of the following for the six months ended June 30, 2026, and June 30, 2025:

Schedule of provision for income tax
	June 30, 2026		June 30, 2025
Current Tax Expense (Benefit)
Federal	$	167	$	1,997
State		1,759		—
Total Current Tax Expense (Benefit)	$	1,926	$	1,997

Deferred Tax Expense (Benefit)
Federal	$	—	$	—
State		—		—
Total Deferred Tax Expense (Benefit)	$	—	$	—

Components of the Fund's Deferred Tax Benefits and Expense as of June 30, 2026, and the year ended December 31, 2025 was as follows:


	June 30, 2026		December 31, 2025
Deferred Income Tax Liabilities:
Unrealized Gain on Investments	$	—	$	(357	)
Subtotal Deferred Income Tax Liabilities	$	—	$	(357	)

Deferred Income Tax Assets:
Capitalized Organization Costs	$	—	$	92
Subtotal Deferred Income Tax Assets	$	—	$	92

Total Net Deferred Income Tax Asset (Liability)	$	—	$	(265	)

The Fund's reported income taxes approximate the expected amount based on federal statutory rates for the six months ended June 30, 2026, and June 30, 2025:

Schedule of federal statutory rates
	June 30, 2026
	Amount		Percent
U.S. Federal Income Tax Expense At Statutory Rate	$	—		—%
U.S. state income taxes ⁽¹⁾		—		—
Non-Taxable Or Non-Deductible Items
Other		1,926		31%
Total Current Tax Expense (Benefit)	$	1,926		31%

	June 30, 2025
	Amount		Percent
U.S. Federal Income Tax Expense At Statutory Rate	$	1,997		21%
U.S. state income taxes ⁽¹⁾		—		—
Non-Taxable Or Non-Deductible Items
Other		—		—%
Total Current Tax Expense (Benefit)	$	1,997		21%

Income Tax Paid By Jurisdiction


	June 30, 2026		June 30, 2025
U.S. Federal	$	5,000	$	2,025
U.S. State⁽¹⁾		1,759		—
Total Income Taxes Paid	$	6,759	$	2,025

⁽¹⁾

State cash tax paid is not applicable as there are no state filing requirements for the Fund as of June 30, 2026, nor were any state filing requirements identified as of June 30, 2025. The above amount represents the state extensions paid in anticipation of tax year 2025 filing requirements for the Fund.

For the tax period ended June 30, 2026, the Fund had $11.6 million in distributions declared of which $10.0 million is characterized as qualified interest income and $1.6 million is, characterized as ordinary dividends. Due to the Fund's intention to elect and qualify as a RIC under the Code, beginning with its fiscal year ending December 31, 2026, the Fund did not have any distributable earnings on a tax basis as of June 30, 2026.