SIF Table

Practical use- Hedge funds
- Private equity and venture capital
- Real estate transactions
Applicable legislationLaw of 13 February 2007 (“SIF Law”)
Eligible investorsWell-informed investors
Eligible assetsUnrestricted.
Any kind of assets can be integrated or any type of investment strategies may be pursued.
Risk diversification requirementsRisk diversification requirements are
defined by CSSF Circular n° 07/309.
Such requirements are less stringent
than the ones applicable to UCITS
and UCI.
In particular, a SIF is not allowed to
invest more than 30% of its net
assets in securities of the same type
of issuer.
Legal Form- FCP
- SICAV (SA, Sàrl, SCA, SCoSA)
- SICAF (SA, Sàrl, SCA, SCoSA)
The entities may be open-ended or
Segregated compartmentsYes
Capital requirementsEUR 1,250,000 to be reached within
12 months from the approval by the
Luxembourg regulator.
Net asset value (NAV) calculation and redemption policyAt least once a year for reporting
Corporate income taxNo corporate income tax
Subscription tax- Rate: 0.01% of the NAV
- Tax exemptions: certain money market and pension funds or SIFs investing in other
funds which are already subject to subscription tax.
Wealth taxNo wealth tax.
Withholding tax on dividends / interests and capital gainsNot subject to withholding tax except
if EU Savings Directive applies.
Benefit from double tax treaty network- Limited to funds set-up in the form of a SICAV / SICAF only.
- Limited to certain double tax treaties.
Benefit from the EU Parent Subsidiary DirectiveNo
Authorisation and supervision by the CSSFYes
Possibility of listingYes
European passportNo unless it falls under the scope of the full AIFMD regime
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