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

Dimension Singapore VCC Cayman SPC Cayman ELP Lux SICAV Lux RAIF Irish ICAV HK OFC HK LPF
Governing law and start VCC Act 2018; framework from 15 Jan 2020 Companies Act Part XIV, in force 1998 ELP Act (Revised) Law of 17 Dec 2010 (Part I or II); SIF regime Law of 23 Jul 2016 ICAV Act 2015 SFO as amended 2016; from 30 Jul 2018 Cap. 637; from 31 Aug 2020
Legal personality Yes Yes; portfolios are not separate entities No Yes Depends on form (an FCP has none) Yes Yes No
Corporate or partnership Corporate Corporate Partnership Corporate FCP, company or partnership Corporate Corporate Partnership
Umbrella and segregation Sub-funds with statutory segregation Unlimited segregated portfolios Check with Cayman counsel Compartments ring-fenced by product law Unlimited ring-fenced sub-funds Umbrella; s35 segregated liability Umbrella permitted; segregation per OFC Rules, confirm Check with HK counsel
Registrar / regulator of the vehicle ACRA; MAS for manager and AML Registrar; CIMA if a regulated fund Registrar; CIMA if a private fund CSSF Not CSSF; listed with the RCS Central Bank (registrar and authoriser) SFC; Companies Registry Companies Registry
Manager requirement Fund manager regulated by MAS Confirm under CIMA regime Confirm under CIMA regime See CSSF Authorised AIFM; no internal management See Central Bank Type 9 licensed or registered Eligible investment manager
Custodian / depositary Depends on scheme type, confirm Confirm Confirm See CSSF Confirm See Central Bank Mandatory custodian Confirm
Headline fund-level tax Taxed as a company; 13O/13U if conditions met No direct taxes on corporations No direct taxes; undertaking up to 50 years Subscription tax 0.05% or 0.01% a year Subscription tax 0.01% a year (default) No Irish tax on declared non-residents Unified fund exemption, if conditions met Unified fund exemption, if conditions met
Treaty access at vehicle level COR in umbrella name, max 5 sub-funds per application Confirm Confirm Certificates not issued per compartment Confirm per treaty 75 DTAs in effect Depends on each CDTA Confirm
Official registration fee S$8,015 + S$400 per sub-fund CI$1,200 to CI$3,068 CI$1,000; annual CI$1,400 or CI$2,200 Per CSSF fee schedule Confirm Per Central Bank fee schedule Private: HK$5,000 or HK$10,000 + HK$1,250 per sub-fund; CR HK$3,034 HK$2,555 + HK$479
Published processing time 14 to 60 days Not published, confirm About 5 business days See CSSF No CSSF approval step 10 business days (registrar review) Private under 1 month; public 1 to 3 months Normally 4 working days
Investor eligibility (headline) Set by SFA offer rules Set by CIMA regime and offer rules Set by CIMA regime and offer rules Part I UCITS can be retail; Part II and SIF differ Well-informed investors UCITS or AIF rules Public (authorised) or private Private funds

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.

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.

Sources and dates

  1. Step 1: Understanding VCC features, eligibility & requirements — Accounting and Corporate Regulatory Authority (ACRA) · 2026-01-29
  2. Step 5a: Registering a variable capital company (VCC) — Accounting and Corporate Regulatory Authority (ACRA) · 2026-10-19
  3. A Note from Indranee Rajah S.C. — The VCC: A Game-Changer for Singapore's Funds Industry — Ministry of Finance, Singapore · 2018-10-02
  4. e-Tax Guide: Tax Framework for Variable Capital Companies (Fourth Edition) — Inland Revenue Authority of Singapore (IRAS) · 2026-04-22
  5. List of DTAs, Limited DTAs and EOI Arrangements — Inland Revenue Authority of Singapore (IRAS) · 2026-02-04
  6. Fees (Companies Act fee schedule) and Exempted Limited Partnership Act Fee Schedule — Cayman Islands General Registry · 2025-04-16
  7. Segregated Portfolio Companies (Cayman Islands) — Conyers (law-firm guidance, secondary source) · 2025-11
  8. Cayman Islands exempted limited partnerships — Ogier (law-firm guidance, secondary source) · 2026-06-01
  9. Worldwide Tax Summaries – Cayman Islands: Taxes on corporate income — PwC (tax summary, secondary source) · 2026-05-29
  10. The Reserved Alternative Investment Fund (RAIF) — CMS Luxembourg (law-firm guidance, secondary source) · 2024-07-12
  11. Worldwide Tax Summaries – Luxembourg: Other taxes — PwC (tax summary, secondary source) · 2026-07-31
  12. Conventions internationales en vigueur et en négociation; Organismes de placement collectif (OPC) — Administration des contributions directes, Luxembourg · 2026-07-23
  13. ICAV Registration — Central Bank of Ireland · 2026-10-24
  14. Irish Collective Asset-management Vehicles Act 2015 (Revised) — Law Reform Commission, Ireland · 2022-07-06
  15. Double Taxation Treaties — Revenue Commissioners, Ireland · 2026-02-18
  16. Worldwide Tax Summaries – Ireland: Other issues — PwC (tax summary, secondary source) · 2026-08-11
  17. Open-ended fund companies; OFC structure — Securities and Futures Commission (SFC) · 2026-10-24
  18. Limited Partnership Fund FAQ — Companies Registry, Hong Kong · 2026-10-24
  19. DIPN No. 61: Profits Tax Exemption for Funds — Inland Revenue Department, Hong Kong · 2020-06
  20. Comprehensive Double Taxation Agreements / Arrangements concluded — Inland Revenue Department, Hong Kong · 2026-10-24
  21. Law of 17 December 2010 relating to undertakings for collective investment (consolidated English text, Article 181) — CSSF (consolidated text for information; official version in the Journal officiel) · 2026-10-24 (accessed)