Why Gibraltar
Why Gibraltar for investment funds?
Gibraltar offers a dual fund regime — Private Funds and Experienced Investor Funds — regulated by the GFSC under English common law, with no capital gains tax, no stamp duty on shares, and a 15% territorial corporation tax rate that typically leaves fund vehicles with minimal Gibraltar tax exposure.
Fund structures
The Gibraltar dual fund regime
Gibraltar's Financial Services (Collective Investment Schemes) Act 2011 and the Experienced Investor Funds Regulations 2020 underpin two distinct regulated vehicles, each suited to different manager types and investor bases.
Private Fund
A Private Fund is available where investors are either limited to 50 in number or each investor subscribes a minimum of £100,000. Shares must not be publicly offered. The Private Fund is the most accessible entry point for emerging managers and closely held structures. Authorisation is typically granted within 10 business days of a complete submission. Annual fees to the GFSC are modest relative to comparable offshore jurisdictions.
Experienced Investor Fund (EIF)
The EIF is available to experienced investors and imposes no investor count cap. It can take the form of an open-ended company, a closed-ended company, a limited partnership, or a unit trust. The EIF regime accommodates a broad range of strategies including private equity, credit, real estate, and digital assets. A full fund offering document and audited accounts are required. The GFSC reviews applications within approximately 4–8 weeks depending on complexity.
Small AIFM structures
Fund managers managing assets below the AIFMD thresholds — €100m for leveraged funds, €500m for unleveraged closed-ended funds with five-year lock-ups — may register as Small AIFMs without full AIFMD authorisation. They are still required to appoint a GFSC-licensed fund administrator. This registration pathway reduces regulatory burden while maintaining investor protection standards.
Regulation
GFSC regulatory framework
The Gibraltar Financial Services Commission (GFSC) is a single integrated regulator covering banking, insurance, investment services, fund management, and fund administration. It operates under UK-aligned legislative standards.
Proportionate supervision
The GFSC applies risk-based, proportionate supervision. For fund structures, it reviews the fitness and propriety of the manager and key personnel, the adequacy of the offering documents, and the appointment of key service providers including an authorised administrator, auditor, and legal counsel. The Commission is accessible to applicants and engages on pre-application queries.
Required appointments
Every authorised Gibraltar fund must appoint: a GFSC-licensed fund administrator, an approved auditor, and legal counsel qualified to opine on Gibraltar law. The administrator carries responsibility for NAV calculation, investor register maintenance, AML/KYC, and regulatory filings. The fund must maintain at least one Gibraltar-resident director or equivalent.
Ongoing obligations
Ongoing requirements include annual audited accounts filed with the GFSC, periodic regulatory returns, FATF-compliant AML procedures, and CRS/FATCA reporting where applicable. EIFs must provide investors with audited annual reports within six months of the financial year end. The GFSC publishes a register of authorised funds on its website.
Tax
Tax treatment of Gibraltar funds
Gibraltar's territorial tax system means that funds whose investment income derives from non-Gibraltar sources pay little or no Gibraltar corporation tax in practice.
Corporation tax — territorial basis
Gibraltar levies corporation tax at 15% on profits accruing in or derived from Gibraltar. For a fund holding foreign equities, bonds, or real estate, the investment returns will typically not be sourced in Gibraltar and will therefore fall outside the Gibraltar tax base. Management fees received by a Gibraltar-based manager from a fund may be sourced in Gibraltar and subject to tax, depending on where the management activity occurs.
No capital gains tax
Gibraltar has no capital gains tax. Gains realised on disposal of fund assets — including securities, real property, and digital assets — are not subject to any Gibraltar tax charge, regardless of whether the assets are Gibraltar-sited or foreign.
No VAT on fund management
Gibraltar has no VAT regime. Fund management, administration, and advisory fees are not subject to any consumption tax in Gibraltar. This contrasts with EU jurisdictions where management fee VAT treatment requires careful structuring, and with the UK post-Brexit landscape where fund management VAT exemption has narrowed.
Digital assets and DLT
Gibraltar was the first jurisdiction to introduce a statutory framework for DLT businesses (Financial Services (Distributed Ledger Technology Providers) Regulations 2017). A Gibraltar fund can hold cryptocurrency, tokenised securities, and other digital assets. There is no specific crypto assets tax in Gibraltar; the general territorial corporation tax rules apply. The GFSC has issued guidance on custody, valuation, and reporting for digital asset funds.
Costs
Cost profile versus other jurisdictions
For managers below $100m AUM, Gibraltar is typically the most cost-effective regulated English common law fund domicile.
Formation and regulatory fees
GFSC application fees for a Private Fund are in the range of £1,000–£2,500 depending on structure. Annual supervision fees are substantially lower than equivalent Cayman BVI or Luxembourg fees. There is no capital duty on fund share issuances, no stamp duty reserve tax, and no annual government filing fee beyond the standard Companies Registry annual return.
Cayman Islands comparison
A Cayman Islands exempted limited partnership or SPC requires registration fees to the Cayman Islands Monetary Authority, government annual fees, a registered office in Cayman, and typically separate legal and administrator fees in multiple jurisdictions. Total annual running costs for a small Cayman fund often exceed $50,000 before management fee income is meaningful. Gibraltar structures can typically be maintained for a materially lower total cost.
Luxembourg comparison
Luxembourg RAIFs and SIFs are appropriate for EU distribution strategies but carry materially higher formation costs (often €50,000–€100,000+), CSSF fees, subscription tax (0.01% for institutional share classes), and mandatory depositary bank appointment. For non-EU managers with no requirement for EU passport rights, Luxembourg adds cost without corresponding benefit. Gibraltar has no subscription tax and no mandatory depositary for non-UCITS structures.
Common questions
Gibraltar fund domiciliation — FAQs
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What fund structures are available in Gibraltar?
Gibraltar offers two main regulated structures: the Private Fund and the Experienced Investor Fund (EIF). Private Funds are limited to 50 investors or require a minimum £100,000 subscription per investor. EIFs are open to experienced investors with no investor count cap and can be structured as open-ended or closed-ended vehicles, including limited partnerships, companies, and unit trusts. Both structures are regulated by the GFSC.
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How long does it take to authorise a Gibraltar fund?
A Private Fund can typically be authorised by the GFSC within 10 business days of a complete application. An EIF generally takes 4–8 weeks depending on complexity and query volumes at the GFSC. The Commission operates a proportionate review process and is accessible to applicants and their advisers throughout the authorisation process. Pre-application engagement is welcomed for non-standard structures.
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Does Gibraltar have a small AIFM regime?
Yes. Fund managers below the AIFMD thresholds — €100m for leveraged strategies, €500m for unleveraged closed-ended funds with five-year lock-ups — can register as Small AIFMs in Gibraltar without full AIFMD authorisation. They must still appoint a GFSC-licensed Gibraltar fund administrator. Resilience Group holds the required administration licence and provides the full administration service for Small AIFM-managed structures.
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How are Gibraltar funds taxed?
Gibraltar funds are subject to corporation tax only on income accruing in or derived from Gibraltar. Investment returns from non-Gibraltar sources — foreign equities, overseas bonds, international real estate — are generally outside the Gibraltar territorial tax base. There is no capital gains tax, no VAT on management fees (Gibraltar has no VAT), and no stamp duty on share transfers. For most fund structures, the effective Gibraltar tax cost is very low.
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Can a Gibraltar fund hold crypto or digital assets?
Yes. Gibraltar introduced a statutory DLT framework in 2018 under the Financial Services (Distributed Ledger Technology Providers) Regulations 2017, making it the first jurisdiction with specific DLT business regulation. Gibraltar funds can hold cryptocurrency, security tokens, and other digital assets. The GFSC has issued guidance on custody arrangements and valuation for digital asset portfolios within regulated fund structures.
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How does Gibraltar compare to Cayman or Luxembourg for fund costs?
For sub-$100m managers, Gibraltar is typically the most cost-effective regulated English common law fund domicile. There is no capital duty on fund issuances, no subscription tax, no mandatory depositary requirement for non-UCITS structures, and GFSC regulatory fees are materially lower than Cayman CIMA or Luxembourg CSSF fees. Total annual fund running costs are substantially lower than comparable Cayman or Luxembourg structures. Luxembourg remains preferable where EU distribution is required.
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Who must be licensed to administer a Gibraltar fund?
All Gibraltar authorised funds must appoint a fund administrator licensed by the GFSC under the Financial Services Act 2019. The administrator is responsible for NAV calculation, investor register, AML/KYC onboarding, and regulatory reporting. Resilience Group holds a GFSC fund administration licence. For Small AIFM structures, appointment of a licensed administrator is a condition of registration. Self-administration is not permitted for GFSC-authorised funds.
Related
Services and sectors
Fund Administration
NAV calculation, investor register, regulatory filings, and AML/KYC for Gibraltar-domiciled funds.
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How Resilience Group supports emerging and established fund managers establishing in Gibraltar.
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MLRO services, AML/KYC programmes, and regulatory compliance support for GFSC-regulated entities.
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Considering a Gibraltar fund?
Resilience Group holds a GFSC fund administration licence and works with managers across private equity, credit, real estate, and digital assets. We can advise on structure selection, prepare the GFSC application, and provide ongoing administration.