Ireland’s favourable corporate tax rate, along with supportive intellectual property and research and development incentives, provides significant opportunities for businesses to reduce their effective tax rate. This advantageous environment has established Ireland as a premier location for fund structures, offering efficiency and competitive benefits for global investors.
Ireland also boasts a highly educated workforce and is open to international talent, fostering a diverse and skilled talent pool that drives growth and innovation across industries. This commitment to talent development further strengthens Ireland’s position as a global hub for aviation finance and aircraft leasing. With over 50 leasing companies, including 14 of the world’s top 15 lessors, an Irish-leased aircraft takes off every two seconds, giving Ireland an impressive 65% share of the global leasing market.
Vistra Ireland, contributing 25 years of combined expertise, manages over $40 billion in assets under administration (AUA) and supports more than 450 unique entities, totalling over 750. This strong presence underscores Ireland’s position as a premier centre for aviation finance, fund structuring, and global investment.
What are the different fund structures?
Investment Company/Variable Capital Company | ICAV | Unit Trust | ILP | CCFs
Investment Company/Variable Capital Company
Alternative investment vehicle description
Companies are registered under the Companies Acts. Shareholders have limited liability. Variable capital companies can repurchase their shares and issues share capital must equal the NAV of all underlying assets. Most are set up as public limited companies (PLCs) as they are marketed to the public i.e. UCITS and AIFs.
Key considerations for setting up an Investment Company/Variable Capital Company in Ireland
All UCITS and many Alternative Investment Funds (AIFs) are marketed to the public (retail). Can be listed on a stock exchange.
Tax implications of establishing an Investment Company/Variable Capital Company in Ireland
Not subject to Irish tax on income, gains or distributions to investors.
Irish Collective Asset-Management Vehicle (ICAV)
Alternative investment vehicle description
Provides a tailor-made corporate fund vehicle for UCITS and Alternative Investment Funds (AIFs). Not subject to material investment or borrowing limits or eligible asset criteria.
Key considerations for setting up an ICAV in Ireland
Min initial subscription EUR 100,000. Non-Irish investment companies can migrate into Ireland and become an ICAV as part of a single process. The purpose is to minimise administrative complexity and cost. The appointment of an AIFM and an Irish based Administrator and Depository is required. It can be approved by Central Bank of Ireland within 24 hours following receipt of all documentation except real estate or crypto funds where pre-submission is required.
Tax implications of establishing an ICAV in Ireland
Not subject to Irish tax on income, gains, or distributions to investors.
Unit Trust
Alternative investment vehicle description
Fund structure constituted by a trust deed between a trustee and a management company (manager) under the Unit Trusts Act, 1990. A Unit Trust is not a separate legal entity and therefore the trustee acts as legal owner of the fund’s assets on behalf of the investors. The Unit Trust does not have a legal personality and therefore cannot enter into contracts. Not subject to material investment or borrowing limits or eligible asset criteria.
Key considerations for setting up a Unit Trust in Ireland
Min initial subscription EUR 100,000. A separate management company is required and managerial responsibility rests with the board of this management company. The same management company can be used to manage other structures. Trust deed is the primary legal document. Appointment of an AIFM and an Irish based Administrator and Depository is required. It can be approved by Central Bank of Ireland within 24 hours following receipt of all documentation except real estate or crypto funds where pre-submission required.
Tax implications of establishing a Unit Trust in Ireland
Not subject to Irish tax on income, gains or distributions to investors.
Investment Limited Partnership (ILP)
Alternative investment vehicle description
ILPs consists of a partnership of two or more persons having as its principal business the investment of its cash in assets. An ILP consists of at least one general partner (GP) and one limited partnership (LP). The LP is equivalent to the shareholder in a company while the GP would be the equivalent of the Management Company in a unit trust. Not subject to material investment or borrowing limits or eligible asset criteria.
Key considerations for setting up an ILP in Ireland
Min investment EUR 100,000. Partnership does not have an independent legal existence. No GP capital requirement & the GP does not have to be an Irish entity. The appointment of an AIFM and an Irish based Administrator and Depository required. It can be approved by Central Bank of Ireland within 24 hours following receipt of all documentation except real estate or crypto funds where pre-submission required.
Tax implications of establishing an ILP in Ireland
Tax transparent vehicle, profits treated as arising directly to the LPs. Each partner is entitled to use any tax reliefs and allowances the partnership is entitled to, as agreed between each partner, subject to any tax rules governing the allocation of the reliefs and allowances. It can often access Ireland’s extensive double taxation treaty network allowing potentially reduced rates of foreign withholding taxes.
Common Contractual Fund (CCFs)
Alternative investment vehicle description
Contractual arrangement established under a deed. Investors are co-owners of the assets and a CCF is unitised. CCF is not a separate legal entity and they are not subject to material investment or borrowing limits or eligible asset criteria.
Key considerations for setting up a CCF in Ireland
Min investment EUR 100,000. The appointment of an AIFM and an Irish based Administrator and Depository required. It can be approved by Central Bank of Ireland within 24 hours following receipt of all documentation except real estate or crypto funds where pre-submission required.
Tax implications of establishing a CCF in Ireland
Transparent for tax purposes.
Fund Domiciliation - Resources and insights
