Fund Domiciles
Luxembourg, Singapore, Hong Kong and the Cayman Islands cover the large majority of where private markets funds actually get domiciled today — from EU-passportable vehicles to tax-neutral offshore structures to onshore Asian gateways. Pick a jurisdiction below for vehicle comparisons, set-up steps, service providers and tax treatment — or talk to us about which one actually fits your strategy.
Each domicile below is a deep, standalone guide — but the right starting point is usually a conversation about your investor base, target assets and target markets, not a jurisdiction you already had in mind.
Europe's private markets hub — home to 18 of the world's 20 largest PE managers and roughly 44% of European PE/VC fund domiciliation, with a full EU-wide AIFMD marketing passport and, via ELTIF 2.0, retail access too.
Southeast Asia's onshore gateway — a Variable Capital Company toolkit built for umbrella/sub-fund structures, a 90+ treaty network, and the 13O/13U schemes that bring the effective tax rate on qualifying fund income to zero.
The Greater China gateway — the LPF gives PE/VC managers a Cayman-ELP-style onshore vehicle, backed by a unified profits tax exemption and a 0% carried interest concession unmatched by most competing hubs.
The default global offshore domicile for closed-end PE and VC — the Exempted Limited Partnership, a tax-neutral regime with no corporate, capital gains or withholding tax, and the fastest realistic path from decision to first close.
A simplified starting point only — each jurisdiction page linked above covers vehicle-by-vehicle detail, tax treatment and set-up steps in full.
| Jurisdiction | Flagship PE/VC vehicle | Regulator | Typical tax on fund income | Typical time to launch | Best suited to |
|---|---|---|---|---|---|
| Luxembourg | RAIF / SCSp | CSSF (direct or via AIFM) | 0% (RAIF-SIF regime, subscription tax only) | 1–6 months | EU-wide marketing, retail access via ELTIF |
| Singapore | VCC / Singapore LP | MAS (manager-level licensing) | 0% on qualifying income under 13O/13U | 3 months – 2 years (licensing-dependent) | ASEAN/APAC gateway, onshore substance |
| Hong Kong | Limited Partnership Fund | SFC (manager-level Type 9) | 0% under the Unified Fund Exemption | ~1 week (vehicle) + 4–9 months (licensing) | Greater China / Mainland access |
| Cayman Islands | Exempted Limited Partnership | CIMA (fund-level registration) | 0% — fully tax-neutral, no direct taxes | 4–8 weeks | Global institutional LPs, maximum flexibility |
Most managers approach jurisdiction choice backwards — picking a domicile first, then discovering the structuring, licensing and provider decisions that come with it. We work the other way: strategy and investor base first, jurisdiction second.
An honest comparison against your actual investor base, target assets and target markets — not a default answer based on where we happen to have relationships.
From choosing the right vehicle to coordinating legal counsel, we help you get from decision to launch in any of these four jurisdictions.
Structured, benchmarked selection across administration, custody/depositary, audit and banking — with vetted shortlists, not a single referral.
Once launched, we help manage the relationships that keep a structure running smoothly, wherever it's domiciled.
It depends on your investor base, target markets and vehicle needs. Luxembourg suits managers raising from European institutions and family offices and wanting an EU-wide marketing passport. Singapore and Hong Kong suit managers building an Asia-Pacific presence — Singapore via the VCC and its treaty network, Hong Kong via the LPF and access to Mainland China through the Mutual Recognition of Funds scheme. The Cayman Islands remains the default tax-neutral vehicle for globally distributed private equity and venture capital funds, especially where U.S. LPs are involved.
Yes — this is common rather than exceptional. Many managers pair a Cayman master fund with a Luxembourg or Singapore feeder to access European or Asian investors, or run parallel structures side by side. Mangis Bay helps design and coordinate these multi-jurisdictional setups so the pieces work together rather than duplicating cost and compliance.
Timelines vary by jurisdiction and vehicle. Unregulated structures — a Luxembourg SCS/SCSp, for example — can launch in one to three months. Directly regulated vehicles such as a Luxembourg SIF or a Cayman fund registered with CIMA typically take three to six months, driven mainly by regulatory approval and service-provider onboarding. See each jurisdiction page for specifics.
We provide independent advice on structure selection, shortlist and vet AIFMs, depositaries, fund administrators and auditors against your strategy, appoint experienced independent directors, and manage the ongoing regulator liaison — CSSF, MAS, SFC or CIMA — once you're live.
Generally not for the fund vehicle itself, but genuine economic substance — local decision-making, board meetings actually held in the jurisdiction, and in most cases locally resident directors — is required almost everywhere. The specifics differ by jurisdiction; we help structure this properly from the outset rather than as an afterthought.