RAIF Table
| RAIF | |
|---|---|
| Practical use | Hedge funds, private equity funds, VC funds, real estate funds, infrastructure funds, microfinance funds, socially responsible funds, etc. |
| Applicable legislation | Law of 23 July 2016 ("RAIF Law") |
| Eligible investors | Well-informed investors. |
| Eligible assets | Unrestricted, unless it invests in a portfolio of risk capital (such as a Sicar). |
| Risk diversification requirements | Risk diversification requirements are aligned with those applicable to SIFs, unless the RAIF chooses to invest in risk capital only and such choice is mentioned in its constitutive documents. |
| Legal Form | FCP - SICAV (SA, Sàrl, SCA, SCoSA) - SICAF (SA, Sàrl, SCA, SCoSA) The entities may be open-ended or closed-ended. |
| Segregated compartments | Yes |
| Capital requirements | - FCP: EUR 1,250,000 to be reached within 12 months from the entry into force of the management regulations. - SICAV: EUR 1,250,000 to be reached within 12 months from the incorporation of the SICAV. |
| Net asset value (NAV) calculation and redemption policy | At least once a year for reporting purposes. |
| Corporate income tax | No income tax, unless investing only in risk capital, then SICAR tax regime applicable. |
| Subscription tax | - Rate: 0.01% of the NAV - Exemptions apply. |
| Wealth tax | No wealth tax |
| Withholding tax on dividends / interests and capital gains | Not subject to withholding tax. |
| Benefit from double tax treaty network | RAIF investing a portfolio of risk capital (such as a SICAR) Access if set-up as a corporate entity (except if set-up under the form of a SCS/SCSp) - RAIFs not investing in a portfolio of risk capital (such as a SICAR, but set-up as: SICAV/SICAF: limited to certain double tax treaties (see circular L.G. A number 61 of the tax administration of 8 December 2017. |
| Benefit from the EU Parent Subsidiary Directive | No, unless RAIF that invests in a portfolio of risk capital (such as a SICAR). |
| Authorisation and supervision by the CSSF | No |
| Possibility of listing | Yes |
| European passport | Yes |
| Thin capitalization rules (debt-to-equity ratio) | No debt-to-equity ratio. |
| Required Luxembourg service providers | - Management Company in case of an FCP - Depositary institution - Administrative agent - Registrar and Transfer Agent |
