Singapore VCC vs Luxembourg SICAV and RAIF

A Luxembourg SICAV (société d'investissement à capital variable) is an investment company with variable capital, used across several Luxembourg product regimes; a RAIF (reserved alternative investment fund) is an alternative fund for well-informed investors that is not supervised by the CSSF but must be run by an authorised AIFM. The Singapore VCC resembles a SICAV in legal form — a company with variable capital and ring-fenced sub-funds — but sits in a different regulatory system: ACRA registers it and a MAS-regulated manager runs it. This page compares legal and regulatory features; it does not rank domiciles.

Luxembourg's fund menu at a glance

Luxembourg separates the product regime (which law governs the fund and who supervises it) from the legal form (company, partnership or contractual fund). A SICAV is a legal form; it can be used under several regimes. Luxembourg's tax administration refers, for example, to Part I SICAVs, Part II SICAVs and SICAV-SIFs (ACD, OPC page, 2025).

The main regimes are Part I of the 2010 Law (UCITS, which can be offered to retail investors), Part II (other UCIs, typically alternative funds), the SIF regime for well-informed investors, the SICAR regime for risk capital and the RAIF, which the CSSF does not count because it does not supervise it. The CSSF reports 2,824 UCIs under Part I, Part II and the SIF regime, with net assets of EUR 6,686.57 bn as at 31 July 2026, and 281 authorised investment fund managers as at 31 August 2026 (CSSF, Main updated figures regarding the financial centre, September 2026). MAS counts VCCs on a different basis, so the figures should not be compared as a ranking.

Singapore has no equivalent split of product regimes for the VCC. The same VCC Act applies whether the VCC is offered to accredited investors or authorised for retail sale; the difference lies in the offering rules and, for authorised schemes, in board composition (at least three directors, one independent, per ACRA).

The RAIF in detail

According to Luxembourg law-firm guidance (CMS, updated 12 July 2024):

• Introduced by a law of 23 July 2016, a RAIF is "not subject to the supervision of the Commission de Surveillance du Secteur Financier (CSSF)" and is entered on the official RAIF list held by the Trade and Companies Register.
• It must appoint an authorised alternative investment fund manager (AIFM); "RAIFs cannot be internally managed", so oversight reaches the RAIF through its AIFM.
• It is "reserved for well-informed investors" (a non-institutional investor can qualify, among other routes, by investing at least EUR 100,000), and net assets "may not be less than EUR 1,250,000", to be reached within 24 months.
• It may be a single fund or an "umbrella structure with an unlimited number of ring-fenced sub-funds".

The VCC follows a similar logic: a privately offered VCC needs no product authorisation from MAS, and oversight runs through the MAS-regulated fund manager the VCC Act requires. The practical difference for Asia-based sponsors is that a RAIF needs an authorised AIFM, often a third-party one, whereas a VCC can be managed by the sponsor's own MAS-regulated entity. How far functions can be delegated back to Asia is a question for Luxembourg counsel.

VCC, SICAV and RAIF side by side

"See CSSF" marks figures this site has not verified, such as SICAV minimum capital and CSSF approval timelines; confirm them with Luxembourg counsel.

The supervision and levy rows carry the real differences. A SICAV is supervised by the CSSF as a product, while the VCC and the RAIF both rely on a regulated manager rather than product approval, which is why the RAIF is often the closer Luxembourg comparison for a privately offered VCC. The levy row is a design difference, not a ranking: Luxembourg charges an annual tax on net assets, whereas Singapore applies income tax rules with conditional fund schemes. The investor row matters most for distribution, since only a Part I SICAV is built for retail sale across the EU.

Sub-funds and compartments

Both systems ring-fence pools inside one entity. In Singapore, "the assets of one sub-fund cannot be used to discharge the liabilities of another sub-fund", and each sub-fund must be wound up separately (MOF note, 2018). In Luxembourg, Article 181 of the Law of 17 December 2010 allows a UCI to have multiple compartments, "each compartment corresponding to a distinct part of the assets and liabilities of the UCI"; the rights of investors and creditors of a compartment are limited to that compartment's assets unless the fund's documents provide otherwise, and each compartment "may be liquidated separately" (CSSF consolidated text, accessed 24 October 2026).

One live development: according to Dechert commentary (August 2026), Bill No 8814, submitted on 30 July 2026, would extend compartment segregation to Luxembourg limited partnerships (SCS and SCSp) that sit outside the product laws. It was still in the legislative process when this page was updated, so treat it as proposed, not enacted.

In both places, whether courts outside the domicile respect the ring-fence is a question for counsel; the legal form and umbrella page covers it across all eight vehicles.

Tax at the fund level

According to PwC's Worldwide Tax Summaries (reviewed 31 July 2026), Luxembourg funds pay an annual subscription tax (taxe d'abonnement): "institutional funds and monetary funds are subject to an annual rate of 0.01%", and "the other funds to an annual rate of 0.05%", calculated on total net assets at the end of each quarter, with exemptions for some categories such as certain ETFs and funds of institutional funds. CMS guidance states that a RAIF under its default regime pays "an annual subscription tax of 0.01% on their net assets".

Singapore has no subscription tax: IRAS treats a VCC, and an umbrella VCC as a single entity, as a company for income tax (e-Tax Guide, 22 April 2026), and the 13O or 13U schemes apply only with approval and conditions (MAS FDD Cir 05/2026). See tax and treaty access.

Neither regime determines what investors pay at home. Applies to: Singapore and Luxembourg; EU, Hong Kong and mainland Chinese investors need advice in their own jurisdiction. General information, not tax advice.

Treaties and residence certificates

The number of treaties matters less than whether the fund itself can use them.

Treaty access depends on the vehicle, the treaty partner's rules and the facts; obtain advice in each jurisdiction. The tax and treaty access page sets out the questions to put to advisers.

Distribution reach and the EU

For many sponsors the deciding factor is not tax but where the fund will be sold. A Luxembourg UCITS can be marketed across the EU under the UCITS passport, and EU AIFMs can market EU alternative funds to professional investors under the AIFMD passport; non-EU structures such as a VCC generally rely on each country's private placement rules. Directive (EU) 2024/927 ("AIFMD II"), with a transposition deadline of 16 April 2026, amends both regimes, so confirm the current position with EU counsel. A VCC's fit depends mainly on where the manager is licensed and where investors are. The investor perception page discusses how to test the investor map before choosing. To discuss your situation, register your enquiry through the contact details on this site.