Where to set up your fund: the major fund jurisdictions compared

Luxembourg

The leading European fund domicile by assets. Often suits larger or institutional raises where recognition across the EU matters most, at a higher cost.

• The reserved alternative investment fund (RAIF) needs no prior approval from the regulator, the CSSF.
• A RAIF must appoint an authorised alternative investment fund manager and a depositary.
• Open only to well-informed investors, with minimum capital of EUR 1.25 million.

Ireland

The other main EU domicile, popular with North American managers. Often suits funds marketed to professional investors across Europe.

• The qualifying investor alternative investment fund (QIAIF) can be approved by the Central Bank the next business day on the fast track.
• Usually set up as an ICAV or an investment limited partnership.
• Minimum subscription of EUR 100,000 per investor.

Cayman Islands

A common offshore choice for funds raising from US and international investors, with a well-known legal framework.

• Closed-ended private funds must register with the Cayman Islands Monetary Authority before taking investor money.
• Usually set up as an exempted limited partnership or a company.
• Needs an annual audit by a Cayman auditor, at least yearly valuations and arrangements for custody and cash monitoring.

Jersey

A Channel Islands domicile with a fast, light-touch regime for private funds and easy reach of London and European investors.

• The Jersey Private Fund (JPF) can be authorised by the JFSC within 48 hours.
• Up to 50 professional or eligible investors, with no offering document required.
• Must appoint a Jersey designated service provider.

Guernsey

Often good value for a first fund. A practical, proportionate Channel Islands domicile with experienced administrators and directors.

• The Private Investment Fund (PIF) is registered by the GFSC within one business day of a complete application.
• Up to 50 investors, with no regulatory requirement for a prospectus.
• Must be administered by a Guernsey licensed administrator. Registered funds for wider investor groups are registered within three business days.

United Kingdom

Often suits managers with a strongly UK-focused strategy or investor base who want an onshore structure investors already know.

• Many private funds use a limited partnership, including the private fund limited partnership introduced in 2017.
• A UK manager usually needs FCA authorisation or registration, or uses a third-party host manager.
• Can suit some venture and tax-sensitive strategies.

United States (Delaware)

The usual home for funds raising mainly from US investors.

• Most US private funds are Delaware limited partnerships.
• There is no approval for the fund itself, but a notice filing with the SEC is usual when interests are sold.
• The manager's US regulatory position depends on its size and its investors.

Singapore

A leading Asian fund hub, for managers raising from investors in Asia.

• The variable capital company (VCC) can be open or closed-ended and set up as an umbrella with sub-funds.
• Must be managed by a fund manager licensed, registered or exempted by the Monetary Authority of Singapore.
• Needs at least one director resident in Singapore.

Our approach

We do not push every manager to the same answer. We often recommend Guernsey because it is good value for a first fund, but it is not right for every fund. We will tell you which jurisdiction fits your investors, size and plans for a second fund, and what it is likely to cost there.

We can also talk you through other domiciles, such as the British Virgin Islands and the Isle of Man. Fund rules change, so treat this page as a starting point and confirm the detail with your lawyers before you commit.