Why Gibraltar
Why Gibraltar for investment funds?
Gibraltar has private schemes and Experienced Investor Funds under the Financial Services Act 2019. Private schemes are not GFSC-authorised as collective investment schemes; EIFs are regulated. The 15% territorial corporation tax rate requires fact-specific analysis.
Fund structures
The Gibraltar dual fund regime
Private schemes fall under section 293(4)(b) and Schedule 24 Part 2 of the Financial Services Act 2019; EIFs are governed by the Financial Services (Experienced Investor Funds) Regulations 2020. Companies House Guidance Note 31 explains both.
Private Fund
A private scheme's constituting instrument must not authorise more than 50 participants. Separately, a qualifying private promotion must be communicated to no more than 50 persons, not to the general public, and must satisfy the other conditions in Schedule 24. The scheme is not authorised as a CIS merely by being private. The applicable AIFM rules and any administrator or custody duties require classification.
Experienced Investor Fund (EIF)
An EIF is open to investors who satisfy one of the eligibility routes in regulation 3 of the EIF Regulations 2020. There is no single £100,000 minimum for every investor. An EIF requires a GFSC-authorised administrator and a Gibraltar registered auditor; its establishment is notified under the Regulations.
Small AIFM structures
Small AIFMs register under Gibraltar's AIFM Regulations 2020 where the relevant thresholds and conditions apply. For qualifying self-managed private schemes, regulation 18B requires a local licensed administrator, subject to the GFSC's exemption or alternative licensed-company-manager powers. An external AIFM may have duties under regulation 10A.
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 supervises regulated EIFs and AIFMs under their applicable regimes. Private schemes are not GFSC-authorised as a CIS category, although manager and other regulated-service requirements may apply.
Required appointments
EIFs must appoint a qualified GFSC-authorised administrator and Gibraltar registered auditor. Private-scheme administrator and custody obligations depend on AIFM classification and any available exemption. Directors and managers should take structure-specific advice.
Ongoing obligations
Ongoing returns, audit, AML and CRS/FATCA duties depend on the fund's legal form, EIF status, manager classification and reportable-entity status. Check the applicable rules before describing a filing as universal.
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; Transaction Tax applies to relevant goods from 15 July 2026. It is not a general VAT on services. The indirect-tax treatment of a particular supply and any cross-border tax consequences should be checked rather than assuming all investment structures have no tax cost.
Digital assets and DLT
Gibraltar's original DLT provider framework launched in 2018; the current provider instrument is the Financial Services (Distributed Ledger Technology Providers) Regulations 2020. A fund's ability to hold digital assets depends on its constitutional documents, investor disclosures, strategy and applicable fund-level valuation and custody rules. The DLT provider licence is a distinct perimeter; do not infer a special GFSC crypto-fund valuation rule from it.
Costs
Cost profile versus other jurisdictions
Compare total formation and running costs against the fund's structure and intended distribution markets, not a generic domicile ranking.
Formation and regulatory fees
A private scheme is not authorised by the GFSC as a CIS category; do not budget for a generic private-fund authorisation fee. Company, manager, administrator and EIF costs vary by structure; request an itemised current quote.
Cayman Islands comparison
A Cayman Islands structure has its own registration, regulatory, registered-office, legal and administration costs. Ask for comparable quotes based on the same fund strategy, investor base and service scope before drawing a cost conclusion.
Luxembourg comparison
Luxembourg structures can support EU distribution strategies but their regulatory, depositary, tax and service costs depend on the chosen regime. Gibraltar does not offer an EU AIFMD marketing passport. Compare structure-specific costs and the actual distribution route; depositary requirements for Gibraltar funds depend on the applicable fund and AIFM rules.
Common questions
Gibraltar fund domiciliation — FAQs
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What fund structures are available in Gibraltar?
Private schemes under section 293(4)(b) and Schedule 24 Part 2 of the Financial Services Act 2019 and Experienced Investor Funds under the 2020 EIF Regulations are distinct routes. A private scheme's constitution cannot authorise more than 50 participants; private promotion to no more than 50 persons has separate conditions. EIFs use the experienced-investor tests in regulation 3.
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How long does it take to authorise a Gibraltar fund?
Private schemes are not GFSC-authorised as a CIS category. EIFs follow a regulated establishment-notification route rather than a universal prior-approval timetable; practical setup depends on documents and providers.
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Does Gibraltar have a small AIFM regime?
An EIF must appoint a GFSC-authorised administrator. For private schemes, the 2025 AIFM rules impose a local Part 7-licensed administrator requirement on qualifying self-managed small AIFMs (and through an external AIFM where regulation 10A applies); the GFSC can grant specified exemptions or permit a licensed company manager instead. Classify the vehicle and manager first.
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How are Gibraltar funds taxed?
Gibraltar generally taxes profits accruing in or derived from Gibraltar at 15%. Gibraltar has no VAT regime; Transaction Tax applies to relevant goods from 15 July 2026. Tax treatment of a particular fund depends on its facts.
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Can a Gibraltar fund hold crypto or digital assets?
Potentially, subject to the fund's documents, disclosures and applicable fund-level custody and valuation requirements. The historic DLT provider framework began in 2018, but the current provider regulations date from 2020. A DLT provider licence is not itself a fund authorisation or a substitute for fund-level controls.
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How does Gibraltar compare to Cayman or Luxembourg for fund costs?
Costs depend on the fund vehicle, manager, service providers, assets and distribution strategy. Gibraltar does not offer an EU AIFMD marketing passport, so EU marketing needs analysis of each target state's rules. Obtain comparable quotations and check applicable depositary and custody requirements rather than assuming one domicile is always cheaper.
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Who must be licensed to administer a Gibraltar fund?
An EIF must appoint a GFSC-authorised administrator. For private schemes, the 2025 AIFM rules impose a local Part 7-licensed administrator requirement on qualifying self-managed small AIFMs (and through an external AIFM where regulation 10A applies); the GFSC can grant specified exemptions or permit a licensed company manager instead. Classify the vehicle and manager first.
Related
Services and sectors
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NAV calculation, investor register, regulatory filings, and AML/KYC for Gibraltar-domiciled funds.
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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?
Rampart Corporate Services Limited, a Resilience subsidiary, holds GFSC permission to act as administrator of a collective investment scheme. We can discuss administration requirements and coordinate with your chosen Gibraltar lawyers on legal structure and any GFSC filings. Resilience does not provide legal advice.