Selecting a fund domicile is about more than tax and regulation. Investors often have strong preferences based on transparency, legal familiarity, and practical fund mechanics. Understanding these preferences early can help managers avoid costly restructuring later.
Across Europe, three locations dominate: Luxembourg, Ireland, and the Channel Islands. Each has invested in fund structures and service frameworks to support alternatives.
Luxembourg: long-standing scale and regulatory clarity
Luxembourg remains the leading European domicile by assets under management. It accommodates a wide variety of structures, including Special Limited Partnerships and the Reserved Alternative Investment Fund (“RAIFs”), both popular with private markets managers. Notably, the RAIF allows managers to bring a fund to market quickly without pre-authorisation by the CSSF, making it well suited to time-sensitive launches.
Its location and multilingual environment also support distribution to German, French, and Benelux investors. Business is commonly conducted in English, and the service ecosystem is extensive and well established.
Ireland: infrastructure, language, and international alignment
Ireland continues to attract new fund launches, particularly from North American firms. The Irish Collective Asset-Management Vehicle structure is flexible, tax-efficient, and increasingly preferred by managers launching AIFs or UCITS vehicles.
Ireland’s regulatory approach, English-speaking talent pool, and strong relationships with North American tax advisers make it a practical option for global managers.
Jersey and Guernsey: offshore access without full AIFMD compliance
For managers seeking to reach European investors without building a full European presence, the Channel Islands offer an alternative. Both Jersey and Guernsey allow access via NPPRs, provided certain conditions are met, including MoUs with the target countries. These regimes offer a lighter regulatory footprint and faster time to market.
Comparison of key European fund domiciles
| Feature | Luxembourg | Ireland | Channel Islands (Jersey & Guernsey) |
| Offshore/onshore | Onshore | Onshore | offshore |
| EU Marketing passport | Yes | Yes | No |
| EU NPPR (National Private Placement Regime) | Yes | Yes | Yes |
| Direct taxes applicable to fund | No | No | No |
| Indirect taxes applicable to fund | VAT | VAT | No |
| Cost | $$ | $$ | $ |
Each jurisdiction offers a distinct combination of benefits
Jurisdictional choice should align with fund strategy, investor preferences, and operational complexity. We support fund setup and administration in all key European locations, helping managers evaluate trade-offs with clarity and speed.
Download: Capital raising in Europe: Fund manager’s guide to alternative investments
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