RAIF: Reserved Alternative Investment Fund in Luxembourg
Fast and flexible structuring for well-informed investors
The RAIF (Reserved Alternative Investment Fund) is an alternative investment vehicle reserved for well-informed investors. It benefits from an attractive tax regime without direct CSSF supervision, allowing setup in just a few weeks.
Key metrics
Our tax experts help you structure your optimization in strict compliance with Luxembourg law and OECD/BEPS standards.
Talk to a tax expertKey advantages
- No corporate income tax (CIT)
- No municipal business tax (MBT)
- No net wealth tax (NWT)
- Only 0.01% subscription tax on net assets
- No direct CSSF supervision (fast setup)
- Structural flexibility: SA, SCA, SCS, SCSp, SARL
Qualifying conditions
- Authorized AIFM manager (in Luxembourg or EU)
- Well-informed investors only (professionals or minimum EUR 100,000 investment)
- Mandatory Luxembourg depositary
- External auditor (approved statutory auditor)
- Central administration in Luxembourg
- Risk diversification (30% rule per asset)
Who this regime is for
EUR 100M private equity fund
A manager launches a EUR 100M RAIF to invest in European SMEs. Average net assets over 5 years: EUR 120M.
24.94% CIT + MBT on gains
0.01% on net assets, 0% CIT/MBT
EUR 12,000
RAIF offers near-total tax neutrality at fund level. Investors are taxed in their residence jurisdiction. Speed of setup (without direct CSSF approval) is a major competitive advantage.
Legal basis and OECD compliance
AIFM regulation and transparency
RAIF is subject to the AIFM directive (2011/61/EU) through its manager. It complies with FATCA, CRS transparency standards and AIFM reporting obligations. Economic substance is provided by the authorized manager and mandatory Luxembourg service providers.
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Frequently asked questions
What is the difference between RAIF and SIF?
SIF (Specialised Investment Fund) is directly supervised by CSSF, requiring prior approval (3 to 6 months). RAIF is not directly supervised: oversight goes through its authorized AIFM manager. Setup is therefore faster (4 to 8 weeks).
Who qualifies as a well-informed investor?
Professional investors under MiFID, institutional investors, or natural/legal persons investing at least EUR 100,000 and having declared in writing awareness of vehicle risks.
Can a RAIF be listed on a stock exchange?
Yes, a RAIF can be listed on the Luxembourg Stock Exchange. However, marketing remains limited to well-informed investors, even if shares are admitted to trading.
What are the setup and operating costs?
Setup: EUR 50,000 to EUR 150,000 (legal documentation, launch, AIFM, depositary). Annual recurring costs: 0.5% to 1.5% of net assets (management, administration, depositary, audit, subscription tax).
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Tax treaties
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Our experts analyze your situation and design the tax structure best suited to your objectives, in full compliance.