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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Bookkeeper.lu
A Luxembourg-based team dedicated to the success of your entrepreneurial project.
Mickaël LOC
17 years at the heart of Luxembourg structures.
Managing Director of Financial Services Luxembourg, Mickaël supports entrepreneurs, SMEs and family offices in structuring, creating and managing their Luxembourg entities. Recognized expert, cited in Le Figaro.
No. AE 0/10077274
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17 years experience
Lux. corporate law
Cited in Le Figaro
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Antoine MARCHI
Technology at the service of fiduciary.
Architect and developer of the Bookkeeper.lu platform, Antoine designs the automation, AI and cloud infrastructure tools that enable Financial Services to deliver a fast and reliable digital service.
5+ years experience
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Made in Luxembourg
Everything is done from Luxembourg. Local team, data hosted in Europe, guaranteed compliance.
Other optimization regimes
Explore the other Luxembourg tax mechanisms available.
SOPARFI
Most usedArt. 166 LIRThe most widely used Luxembourg holding vehicle in Europe
IP Box
Art. 50ter LIREffective rate of about 5% on intellectual property income
Fiscal unity
Art. 164bis LIRConsolidate a group fiscally and offset losses between entities
Tax treaties
OECD model and bilateral agreementsOver 80 treaties to avoid double taxation
Tax ruling
§ 29a AO (procedure)Fully secure the tax treatment of your operations
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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Our experts analyze your situation and design the tax structure best suited to your objectives, in full compliance.


