Jersey is a leading international finance centre with significant reputation in the global funds industry. The government and regulator have been proactive and innovative in creating fund regimes that are flexible, dynamic and offer a range of structures that meet the specific needs of fund managers around the world.
Managers are attracted to Jersey for its robust regulatory frameworks, strong governance and substance, political and financial stability, and proximity to the EU and UK – enabling faster global market access through private placement.
Jersey has developed regulations specifically for alternative asset classes and has a proven track record in private equity, venture capital, real estate, infrastructure, hedge funds, and a growing presence in digital assets.
With its open, business-friendly environment, Jersey offers a tax-neutral setting, supported by long-established tax treaties that help avoid double taxation for both funds and investors. Despite these advantages, Jersey remains competitively priced, delivering high-quality service at sensible rates.
Vistra Jersey has more than $29 billion in Funds Assets Under Administration, reinforcing its position as a trusted partner in the global funds industry showcasing our extensive expertise. This includes $5 billion in Private Equity assets, $13 billion in Real Estate assets, and $11 billion in Capital Market assets.
What are the different fund structures?
Jersey Private Fund | Expert Fund | Listed Fund | Eligible Investor Fund | Unregulated Investor Fund.
Jersey Private Fund
Alternative investment vehicle description
Jersey-domiciled fund which is offered to ‘professional’ or ‘eligible’ investors only and can be open or closed-ended.
A Jersey Private is granted a quick and simple consent under the Control of Borrowing (Jersey) Order (“COBO”). Subject to the JFSC having no queries, the COBO consent is issued to qualifying funds within forty-eight hours of the application being received.
Key considerations for setting up a Private Fund in Jersey
- Maximum of 50 initial offers and no more than 50 investors at any time
- The fund must not be listed on a stock exchange
- No requirement to appoint an auditor
- Can be structured as a company, limited partnership, Jersey unit trust, or almost any non-Jersey structure (with appropriate consent)
- Provided that certain criteria are met, the fund doesn’t have to comply with the Code of Practice for Certified Funds; and the promoter of the fund won’t require prior approval from the Jersey Financial Services Commission
- Can be an alternative investment fund (AIF), when Jersey’s AIFMD legislation and code of practice for AIFs and AIF services business will apply
- A Jersey Private Fund must appoint an existing, full-substance, Jersey-based designated service provider (DSP) to ensure that due diligence, relevant anti-money laundering legislation and other necessary requirements are met.
Tax implications of establishing a Private Fund in Jersey
Broadly, gains made on the disposal of assets in a fund aren’t liable to Jersey income tax.
Companies. Jersey fund companies that are residents for tax purposes in the island will be subject to a zero percent rate of income tax.
Limited partnerships. A Jersey limited partnership isn’t assessed for tax in Jersey in its own name. Investors residing in Jersey will be subject to Jersey tax. Investors who aren’t residing in Jersey won’t be subject to Jersey tax but will be taxed in the countries where they are domiciled.
Unit trusts. Funds established as unit trusts are exempt from tax on foreign income and bank interest. Unitholders who aren’t residents for income tax purposes in Jersey aren’t typically subject to Jersey income or capital gains tax. Unitholders resident in Jersey for tax purposes will be liable to Jersey income tax.
Expert Fund
Alternative investment vehicle description
A Jersey-domiciled fund that is subject to a light degree of regulation.
To be approved, the fund administrator certifies that the fund complies with the Jersey Expert Fund Guide and files the fund’s offer document. The JFSC then aims for a three-day turnaround on approval.
Key considerations for setting up an Expert Fund in Jersey
- Investors must fall within one of the categories of ‘Expert Investor’ as detailed in the Jersey Expert Fund Guide.
- No cap on the number of investors in the vehicle.
- The investment manager/adviser must meet a set of specific criteria, which includes being established in an OECD member or any other state or jurisdiction with which the JFSC has entered into a Memorandum of Understanding or equivalent
- Expert funds can be structured as a company, limited partnership or Jersey unit trust
- The fund must appoint an administrator, manager or trustee who has two Jersey-resident directors with appropriate experience, staff and a physical presence in Jersey.
- Can be listed on a stock exchange (subject to certain provisions)
Tax implications of establishing an Expert Fund in Jersey
Broadly, gains made on the disposal of assets in a fund aren’t liable to Jersey income tax.
Companies. Jersey fund companies that are residents for tax purposes in the island will be subject to a zero percent rate of income tax.
Limited partnerships. A Jersey limited partnership isn’t assessed for tax in Jersey in its own name. Investors residing in Jersey will be subject to Jersey tax. Investors who aren’t residing in Jersey won’t be subject to Jersey tax but will be taxed in the countries where they are domiciled.
Unit trusts. Funds established as unit trusts are exempt from tax on foreign income and bank interest. Unitholders who aren’t residents for income tax purposes in Jersey aren’t typically subject to Jersey income or capital gains tax. Unitholders resident in Jersey for tax purposes will be liable to Jersey income tax.
Listed Fund
Alternative investment vehicle description
The Jersey Listed Funds regime is available to funds that comply with the JFSC’s Listed Fund Guide.
Similar to the Expert Fund regime, Listed Funds are subject to very light regulation and can be fast-tracked once an administrator has certified that a fund complies with the Guide.
Key considerations for setting up a Listed Fund in Jersey
- A fund must be listed on a stock exchange or market pre-approved by the JFSC. These are global and include London, New York and Hong Kong.
- Listed funds must be companies incorporated in Jersey
- Funds must be closed-ended
- At least two experienced Jersey-resident directors must be appointed to the board of the fund company.
- A majority of the board must be independent of the promoter.
- The fund must be audited and must appoint a licensed Jersey administrator or manager
- Listed funds can be marketed into the EU/EEA through National Private Placement Regimes in compliance with AIFMD
Tax implications of establishing a Listed Fund in Jersey
Broadly, gains made on the disposal of assets in a fund aren’t liable to Jersey income tax.
Companies. Jersey fund companies that are residents for tax purposes in the island will be subject to a zero percent rate of income tax.
Eligible Investor Fund
Alternative investment vehicle description
Similar to Expert Funds, Jersey Eligible Investor Funds are, as the name implies, available to investors who meet a particular set of criteria.
An Eligible Investor Fund can be open or closed-ended and take the form of a company, unit trust or limited partnership.
Key considerations for setting up an Eligible Investor Fund in Jersey
- To be ‘eligible’, investors must qualify in one out of 11 categories, which include:
- Making a minimum initial investment or commitment of US$1 million (or equivalent)
- A person whose business or professional activity includes dealing in, managing, underwriting or giving advice on investments
- Funds must be alternative investment funds (AIFs)
- Funds may be listed, but only on exchanges or markets that permit transfer restrictions to ensure that only Eligible Investors can acquire the securities or interests
- The fund company, partnership or unit trust must have at least two Jersey-resident directors
- A Jersey Eligible Investor Fund must appoint an auditor
Tax implications of establishing an Eligible Investor Fund in Jersey
Broadly, gains made on the disposal of assets in a fund aren’t liable to Jersey income tax.
Companies. Jersey fund companies that are residents for tax purposes in the island will be subject to a zero percent rate of income tax.
Limited partnerships. A Jersey limited partnership isn’t assessed for tax in Jersey in its own name. Investors residing in Jersey will be subject to Jersey tax. Investors who aren’t residing in Jersey won’t be subject to Jersey tax but will be taxed in the countries where they are domiciled.
Unit trusts. Funds established as unit trusts are exempt from tax on foreign income and bank interest. Unitholders who aren’t residents for income tax purposes in Jersey aren’t typically subject to Jersey income or capital gains tax. Unitholders resident in Jersey for tax purposes will be liable to Jersey income tax.
Unregulated Eligible Investor Fund
Alternative investment vehicle description
Jersey-domiciled fund which is offered to certain eligible investors only, and is largely similar to an Eligible Investor Fund.
Critically, however, Unregulated Eligible Investor Funds fall outside the regulatory regime under the Collective Investment Funds Law, and the requirements of the Certified Funds Code do not apply.
Key considerations for setting up an Unregulated Eligible Investor Fund in Jersey
- As the fund is unregulated and therefore can be launched immediately upon written notice being given to the Registrar confirming that all necessary conditions have been met.
- There is no requirement for a fund to have a Jersey-based administrator or custodian, nor for it to have any Jersey-resident directors. There is also no requirement for Jersey-based auditors to be appointed.
- UEIFs aren’t AIFMD compliant and can’t be marketed to investors in the EU/EEA
- A UEIF can be open or closed-ended and take the form of a company, unit trust or limited partnership.
- In order to be ‘eligible’, investors must qualify in one out of 11 categories, which include:
- Making a minimum initial investment or commitment of US$1 million (or equivalent)
- A person whose business or professional activity includes dealing in, managing, underwriting or giving advice on investments
- Funds may be listed, but only on exchanges or markets that permit transfer restrictions to ensure that only Eligible Investors can acquire the securities or interests
Tax implications of establishing an Unregulated Eligible Investor Fund in Jersey
Broadly, gains made on the disposal of assets in a fund aren’t liable to Jersey income tax.
Companies. Jersey fund companies that are residents for tax purposes in the island will be subject to a zero percent rate of income tax.
Limited partnerships. A Jersey limited partnership isn’t assessed for tax in Jersey in its own name. Investors residing in Jersey will be subject to Jersey tax. Investors who aren’t residing in Jersey won’t be subject to Jersey tax but will be taxed in the countries where they are domiciled.
Unit trusts. Funds established as unit trusts are exempt from tax on foreign income and bank interest. Unitholders who aren’t residents for income tax purposes in Jersey aren’t typically subject to Jersey income or capital gains tax. Unitholders resident in Jersey for tax purposes will be liable to Jersey income tax.
Fund Domiciliation - Resources and insights
