For decades, Jersey has had fund services at the heart of its finance industry, and is recognised globally for having a strong regulatory reputation, a streamlined fund approval process, a tax-neutral framework and a stable, well-regarded legal and political environment.
While not part of the EU, Jersey maintains positive relations with the bloc’s member states. Funds can be marketed to the EU’s investor base through the Alternative Investment Fund Managers Directive (AIFMD) passport and the National Private Placement Regime (NPPR), which allows targeted marketing within individual jurisdictions.
Jersey is home to a significant number of venture capital, private equity, mezzanine, real estate, infrastructure and hedge funds, with alternative asset classes representing 87% of total funds business. The island offers a range of structures that cater to different investor bases – such as the Expert Fund and the Listed Fund – with the Jersey Private Fund (JPF) being its flagship product.
Originally launched in 2017, the JPF was amended in 2025 to make it an even more compelling proposition. It is typically used for alternative strategies and is designed for investment managers seeking a fast and cost-efficient route to market.
The key advantage of the JPF is its 24-hour regulatory turnaround, allowing you to launch quickly while still meeting international governance and investor protection standards.
JPFs can be open- or closed-ended, and marketed into certain EU countries via the NPPR, making them attractive for managers targeting institutional or high-net-worth investors across the UK, Channel Islands, select European jurisdictions and beyond.
The fund also offers considerable structural flexibility, including no mandatory requirement for a custodian, auditor or Jersey-based directors, unless specified by the structure.
- Authorisation within 24 hours
- No limit on offers/investors
- Must be registered by a Jersey-based Designated Service Provider (DSP), such as Hawksford
- Tax neutral with no Jersey tax on non-Jersey income or gains
- Can be a company, limited partnership or unit trust
The Cayman Islands is one of the world’s largest fund domiciles, with more than 30,000 investment funds currently registered with the Cayman Islands Monetary Authority (CIMA). US funds commonly use Cayman Islands structures like master-feeder or side-by-side setups to attract both US and non-US investors.
Cayman’s reputation on the global stage is built on flexibility, trust and a deep ecosystem of professional service providers, such as administrators, lawyers and auditors, with the expertise required to support complex fund strategies.
Funds domiciled in the islands aren’t subject to corporate income tax, capital gains tax or withholding tax – another key factor in their attractiveness. Together, these qualities have made Cayman the preferred destination for hedge funds, private funds and other alternative investment vehicles – with a key structure being those investment funds registered under the Private Funds Act (PFA).
CPFs are, in essence, closed-ended funds that have been registered with CIMA under the PFA and are ideal for private equity, real estate, infrastructure and venture capital strategies. While CPFs need to be registered, they benefit from a light-touch, non-intrusive regulatory regime that allows for efficient, global fund launches.
CPFs are globally recognised by institutional and professional limited partners (LPs) thanks to their regulatory familiarity, and are typically appealing to cross-border fund managers seeking a commercially flexible yet compliant structure.
Although not eligible for AIFMD passporting, CPFs are often used alongside master-feeder or parallel structures with Delaware or Luxembourg entities to access global capital. They must maintain proper valuation, cash monitoring and safekeeping procedures, though these functions can be delegated to service providers.
- Can be established as exempted limited partnerships, companies and LLCs
- Must apply to register with CIMA within 21 days of receiving investor commitments
- No corporate income tax, capital gains tax, withholding tax or inheritance tax on Cayman entities – although tax obligations may apply in home countries
- Annual audit required; asset valuation must be by an independent party or verified as such
Luxembourg is the largest fund centre in Europe and second worldwide after the US in terms of assets under management. It is pre-eminent in the alternative investment funds space, being home to almost two-thirds of Europe’s alternative vehicles.
Politically stable with a AAA credit rating, Luxembourg is known for its robust yet progressive regulatory regime, and is home to a multilingual workforce and a strong ecosystem of service providers with cross-border expertise. As an EU member state, the jurisdiction offers the advantage of EU-wide distribution under the AIFMD passport when your fund is managed by an authorised Alternative Investment Fund Manager (AIFM).
Global managers can choose from a range of alternative fund structures to meet their specific requirements – from the more plain vanilla alternative investment fund (AIF), via the more framed yet flexible Reserved Alternative Investment Fund (RAIF), to the European long-term investment fund (ELTIF).
Introduced in 2016, the RAIF is designed for professional and well-informed investors seeking the benefits of AIFMD compliance with greater speed and flexibility than traditional regulated vehicles. It is especially popular for private equity and real assets due to its attractive tax regime and contractual flexibility.
RAIFs aren’t directly supervised by the Commission de Surveillance du Secteur Financier (CSSF). Instead, they must appoint an authorised AIFM, who assumes responsibility for regulatory compliance. This allows RAIFs to be launched within weeks while still benefiting from EU passporting rights to markets across the European Economic Area.
As they don’t require pre-approval or ongoing oversight from the CSSF, RAIFs provide a balance between institutional-grade governance and pragmatic time-to-market efficiency. They can also be structured as umbrella funds, allowing for multiple segregated sub-funds with different investment strategies.
- Can launch immediately (with AIFM to notify CSSF)
- Can be formed as corporate or partnership structures – with partnership forms offering tax transparency (while remaining liable for subscription tax) and a potential tax exemption if structured as a partnership limited by shares
- Must appoint key service providers, including an authorised AIFM, depositary, auditor and administrator
- AIFMD-compliant, allowing passporting across the EU
Mauritius is a rising star in alternative investment funds and is commonly used for structuring cross-border and international investments, notably into African countries that it shares a double tax treaty with. It offers a stable, democratic political system, a hybrid legal system influenced by both civil and common law practices, and is compliant with global standards, including anti-money laundering (AML).
Mauritius is an attractive fund domicile because it offers a flexible and cost-effective regime, a robust and regulatory framework, well-developed infrastructure, a wider ecosystem of banks and professional services firms, and the availability of skilled professionals. This is enhanced by an extensive tax treaty network, which offers the opportunity to reduce source-country withholding taxes on cross-border investments.
Common fund structures include the Collective Investment Scheme (CIS), a regulated open-ended fund, and the Closed-End Fund (CEF) – both of which can invest in a wide portfolio of alternative assets. The Variable Capital Company (VCC), introduced in 2022, is the most recent innovation.
A Mauritius VCC is a flexible fund structure designed to support a wide range of investment strategies and vehicles. Managers can structure VCCs as standalone funds, protected cell structures or umbrella funds with single or multiple sub-funds and/or special purpose vehicles (SPVs), where each sub-fund may opt to have a legal personality distinct from the VCC.
Importantly, a Mauritius VCC can be authorised as a CIS or CEF, depending on the investment objectives and redemption rights.
The VCC provides significant operational and cost efficiencies, especially if you’re running multi-strategy funds or catering to different investor classes. This is because the VCC Act allows managers to appoint the same service providers – CIS Manager, CIS Administrator and custodian – for all sub-funds, thus building in economies of scale.
- Allows multiple sub-funds and SPVs under one VCC
- Supports open- and closed-ended fund types
- Eligible for partial exemption (3% tax instead of 15%)
- Licensed and overseen by the Mauritius Financial Services Commission
Singapore is a global financial powerhouse and is consistently ranked among the best jurisdictions in the world for its pro-business environment, advanced infrastructure, financial sector development and access to human capital. It’s an ideal location if you’re targeting investors in the Asia-Pacific region.
The city-state’s regulator, the Monetary Authority of Singapore (MAS), takes a progressive approach to the finance sector – creating an environment that balances investor protection and compliance with anti-financial crime standards, with a responsiveness to industry and the need to remain globally competitive.
In recent years, Singapore has moved decisively to enhance its funds regime. This includes launching the Variable Capital Company – which provides managers with a flexible alternative to the existing private limited company, limited partnership or unit trust options – and introducing targeted tax incentives to encourage domiciliation onshore.
Designed specifically for investment funds and introduced in 2020, the Singapore VCC is a modern, flexible fund structure that can accommodate both open-ended and closed-ended strategies. It has proved exceptionally popular since launch, with more than 1,200 VCCs incorporated by March 2025.
The VCC allows for the creation of multiple sub-funds within a single legal entity, each with ring-fenced assets and liabilities, and offers significant operational and cost efficiencies, particularly for fund managers running multiple strategies or targeting different investor types.
VCCs must be managed by a Permissible Fund Manager and are regulated under the Variable Capital Company Act 2018. The Accounting and Corporate Regulatory Authority (ACRA) is the administrating authority for the VCC Act except in relation to anti-money laundering/countering the financing of terrorism, and the regulation of the Fund Manager which is supervised by the Monetary Authority of Singapore (MAS).
The Singapore VCC has rapidly gained traction as the preferred vehicle for fund launches, offering flexible share issuance and redemption, confidentiality of investor registers and alignment with global custody and fund administration best practices. This makes it suitable for managers targeting Asia-Pacific markets, institutional investors and family office capital.
- Umbrella structure allowing multiple sub-funds with segregated assets/liabilities
- The capital of a VCC will always be equal to its net assets, thereby providing flexibility in the distribution and reduction of capital
- Benefits from tax incentives and access to Singapore’s extensive double tax treaty network when structured appropriately
- VCCs provide privacy for investors as they don’t have to publicly disclose their member register
- Existing overseas funds can be re-domiciled to Singapore as a VCC
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