The fund domicile matrix: VCC, Cayman SPC and ELP, Luxembourg SICAV and RAIF, Irish ICAV, Hong Kong OFC and LPF

The fund domicile matrix places eight vehicles from five jurisdictions on one table: the Singapore Variable Capital Company (VCC), the Cayman segregated portfolio company (SPC) and exempted limited partnership (ELP), the Luxembourg SICAV and reserved alternative investment fund (RAIF), the Irish collective asset-management vehicle (ICAV), and the Hong Kong open-ended fund company (OFC) and limited partnership fund (LPF). Each cell states a mechanism or a published official figure.

How to read the matrix

Three conventions apply throughout:

• Dates and currencies. Fees appear in the currency each authority publishes, without conversion except the Cayman Registry's own US$ figures (US$1 = CI$0.82). Sources were checked on or before 24 October 2026.
• Source type. Statutes, regulators and registries are primary sources; where a cell relies on law-firm or tax-firm guidance (Conyers, Ogier, CMS, PwC), the explanation says so.
• "Confirm" cells. The point has not been verified against an official source; ask counsel in that jurisdiction.

This table compares legal and regulatory features; it does not rank domiciles. Which domicile fits depends on investor location and type, strategy, manager location and licensing, and cost tolerance.

The matrix

Legal form and segregation

Governing law and start date

Five of the eight regimes date from 2015 or later (sources: MAS and ACRA, Conyers, CMS, the SFC and the Companies Registry), so case law on them is thinner, a point counsel may raise.

Legal personality and form

Conyers notes that an SPC "is a single legal entity" whose portfolios are not separate entities; Ogier and the Hong Kong Companies Registry state that the ELP and the LPF lack legal personality; a RAIF can be an FCP, a company or a partnership (CMS). Form decides whether investor rights sit in articles or a partnership agreement.

Umbrella and segregation

The Ministry of Finance note on the VCC Bill (2 October 2018) states that the assets of one sub-fund cannot be used to discharge another's liabilities and that each sub-fund is wound up separately. Section 35 of the ICAV Act provides that a sub-fund's liabilities are discharged solely out of its own assets. Under Article 181 of Luxembourg's 2010 UCI Law, each compartment is a distinct part of the fund's assets and liabilities and may be liquidated separately, and RAIFs may have an unlimited number of ring-fenced sub-funds (CMS). Hong Kong OFC segregation is set by the OFC Rules and OFC Code; confirm with Hong Kong counsel. Recognition of segregation by foreign courts is a separate legal question. See legal form and umbrella structures.

Regulation and service providers

Who registers or supervises the vehicle

ACRA registers the VCC while MAS regulates its manager; the SFC registers every OFC while the Companies Registry incorporates it; the Central Bank of Ireland is both ICAV registrar and authoriser, as separate functions; and a RAIF is "not subject to the supervision" of the CSSF, though its AIFM is (CMS). Registration is not an endorsement of any fund. See who regulates the fund.

Manager and custodian

A VCC must appoint "a fund manager that is regulated by MAS" (MAS and ACRA, 2020); an OFC needs a Type 9 manager and a custodian for all scheme property (SFC); a RAIF "cannot be internally managed" (CMS); and an LPF's investment manager must be a Hong Kong resident, company or registered non-Hong Kong company (Companies Registry). Other cells depend on fund type and should be confirmed locally.

Tax and treaties

Headline fund-level tax

The tax row draws on IRAS and MAS (VCC; the 13O and 13U schemes apply only if conditions are met), PwC (Cayman, Luxembourg and Ireland, secondary), Ogier (the ELP tax undertaking of up to 50 years), CMS (the RAIF's 0.01% default) and IRD DIPN 61 (Hong Kong's unified fund exemption). Investors and managers stay taxable where resident.

Treaty access at vehicle level

What matters is whether the vehicle itself can obtain a residence certificate: IRAS issues a VCC's certificate in the umbrella's name, listing up to five sub-funds per application, while Luxembourg does not issue certificates per compartment. Treaty counts, each on its authority's own basis, are on the fund taxation and treaty access page.

Official fees and published timing

Fees

The VCC figure is S$15 for the name plus S$8,000 for incorporation (ACRA Step 1 page, 29 January 2026). The Cayman SPC fee depends on authorised share capital, under the Registry schedule effective 1 January 2025. The OFC figures are private-OFC SFC fees plus the Companies Registry's HK$3,034. CIMA, CSSF and Central Bank fees follow their own schedules. Per-sub-fund fees matter for umbrella plans.

Published processing times

ACRA says VCC registrations "take 14 to 60 days to approve". The Central Bank's ten business days apply to a complete ICAV registration only, not fund authorisation, and the ELP figure comes from Ogier guidance. None of these clocks includes manager licensing, bank onboarding or investor documents. See set-up time and official fees.

What the matrix cannot tell you

The matrix does not show investor familiarity, the depth of local service providers, how a given investor's tax rules treat each vehicle, or how long the whole project takes, and it cannot capture rule changes after the dates shown. Nor does it weigh the rows: for most sponsors the manager-requirement and investor-eligibility rows eliminate vehicles before fees or processing times matter. Use it to narrow a shortlist to two or three vehicles, then work through the eight-step method and the vehicle-by-vehicle pages for Cayman, Luxembourg, Ireland and Hong Kong.

Jurisdictions covered: Singapore, Cayman Islands, Luxembourg, Ireland and Hong Kong. This is general information, not tax or legal advice; investors in other countries, including mainland China, need advice under their own law. To discuss your situation, register your enquiry through the contact details on this site.