Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the fund launch, including banking and payment rails.
Investment fund in Luxembourg: RAIF, SIF and the AIFM route.
An investment fund in Luxembourg can skip the approval queue as a RAIF under the Law of 23 July 2016: no CSSF product approval, because supervision sits with the authorised AIFM that must manage it. Net assets must reach EUR 1,250,000 within twenty-four months. Investors must be well-informed, from EUR 100,000. Subscription tax is 0.01%. The SIF remains for supervised products.
30 yrs
of experienceof experience
60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated · Reviewed by the Prifinance team
Luxembourg in brief
Investment fund in Luxembourg: the fund that launches at the speed of its manager.
Luxembourg's reserved alternative investment fund solved the problem that used to define fund launches: waiting for the regulator to approve the product. Under the Law of 23 July 2016, a RAIF is not subject to supervision by a Luxembourg supervisory authority - Article 39 requires the fund to say so plainly in its documents, and it operates on a registration model rather than pre-approval. What makes that acceptable is where the supervision actually sits: Article 4 requires the RAIF to be managed by an authorised alternative investment fund manager, in Luxembourg, elsewhere in the EU or in a third country under the AIFMD. The regulator supervises the manager; the manager is responsible for the fund.
The numbers are set in the Law itself. Net assets must reach EUR 1,250,000 within twenty-four months of constitution. Investors must be well-informed: either they adhere in writing and invest at least EUR 100,000, or a credit institution or investment firm assesses their expertise. The annual subscription tax is 0.01 per cent. Around that sit Luxembourg's real advantages - the largest fund administration industry in Europe, depositaries and auditors within walking distance, and legal forms that accommodate private equity, real estate, debt, and umbrella structures with compartments. Where a supervised product is genuinely needed, the SIF and the Part II fund remain available. We choose the vehicle, appoint the AIFM and depositary, and launch.
Europe's fund capital without the approval queue: the RAIF under the Law of 23 July 2016 - no Luxembourg product supervision (stated in the documents per Article 39), because an authorised AIFM must manage it.
EUR 1,250,000 of net assets within 24 months, well-informed investors from EUR 100,000, subscription tax of 0.01% per annum, umbrellas with ring-fenced compartments, and Europe's deepest fund service industry.
The two builds
The RAIF - or the supervised fund.
Speed or supervision: the RAIF launches without product approval under an authorised AIFM; the SIF is CSSF-supervised at product level. Investor expectations decide.
The RAIF for speed - or a CSSF-supervised fund.
01 - RAIF
The fast vehicle
The reserved alternative investment fund under the 2016 Law - no CSSF product approval, EUR 1,250,000 of net assets within twenty-four months, an authorised AIFM above it and 0.01% subscription tax.
The reserved alternative investment fund under the 2016 Law - no CSSF product approval, EUR 1,250,000 of net assets within twenty-four months, an authorised AIFM above it and 0.01% subscription tax.
- ✓Law of 23 July 2016
- ✓EUR 1,250,000 in 24 months
- ✓Authorised AIFM required
- ✓Well-informed investors, EUR 100,000
- ✓0.01% annual subscription tax
- ✓Registration, not pre-approval
02 - SIF / SUPERVISED FUND
The regulated product
The specialised investment fund and other CSSF-supervised vehicles. Where investors, mandates or distribution require product-level supervision rather than manager-level only.
The SIF and other supervised vehicles where an institutional mandate or distribution channel requires product-level supervision rather than manager-level only.
- ✓CSSF product supervision
- ✓Specialised investment fund regime
- ✓Institutional mandates satisfied
- ✓Longer launch timetable
- ✓Same administration ecosystem
- ✓Chosen on investor requirements
Figures per the Law of 23 July 2016. Minimum net assets in Articles 20, 25 and 32, AIFM requirement in Article 4, well-informed investors in Article 2, subscription tax in Article 46, disclosure of non-supervision in Article 39.
Why Luxembourg
Six reasons sponsors launch here.
✓
No product approval queue
A RAIF is not subject to Luxembourg product supervision. Launch timing depends on the sponsor and the AIFM, not on a regulator's calendar.Launch on your clock.
✓
Supervision where it belongs
The authorised AIFM above the fund is regulated. Investors get oversight of the decision-maker rather than of the wrapper.Oversight where decisions are.
✓
Europe's fund infrastructure
Administrators, depositaries, auditors and fund lawyers in one small city. Assembly is a series of meetings, not flights.One city, every provider.
✓
0.01% subscription tax
The annual charge on the fund is set at one basis point by the Law. Predictable and negligible against performance.One basis point.
✓
Umbrella and compartments
One vehicle, many ring-fenced compartments. Strategies and investor groups separated without separate launches.Many strategies, one fund.
✓
A name investors know
Luxembourg is where European institutional money expects funds to be domiciled. The diligence question rarely gets asked.Diligence rarely asks.
How it compares
How Luxembourg differs from other fund domiciles.
The comparison in plain terms: institutional infrastructure and speed. At institutional cost, with an AIFM you must actually have.
Luxembourg vs other fund domiciles
| Feature |  Luxembourg RAIF | Other domiciles |
|---|---|---|
| Product approval | None - manager supervised | Regulator approves the fund |
| Minimum net assets | EUR 1,250,000 in 24 months | Varies or none |
| Investors | Well-informed, EUR 100,000 | Professional or all |
| Annual charge | 0.01% subscription tax | Fixed registry fees |
Product approval
Luxembourg RAIFNone - manager supervised
Other domicilesRegulator approves the fund
Minimum net assets
Luxembourg RAIFEUR 1,250,000 in 24 months
Other domicilesVaries or none
Investors
Luxembourg RAIFWell-informed, EUR 100,000
Other domicilesProfessional or all
Annual charge
Luxembourg RAIF0.01% subscription tax
Other domicilesFixed registry fees
Country by country
| Country | Vehicle | Regulator | Notes |
|---|---|---|---|
| Luxembourg | RAIF · SIF | CSSF supervises the AIFM | EUR 1.25M in 24 months |
 Cayman Islands | Mutual and private funds | CIMA | CI$4,125 annual registration |
 Ireland | ICAV and QIAIF | Central Bank of Ireland | European alternative |
 Malta | PIF and notified AIF | MFSA | Lower cost base |
LuxembourgVehicleRAIF · SIF
RegulatorCSSF supervises the AIFM
NotesEUR 1.25M in 24 months
Cayman IslandsVehicleMutual and private funds
RegulatorCIMA
NotesCI$4,125 annual registration
IrelandVehicleICAV and QIAIF
RegulatorCentral Bank of Ireland
NotesEuropean alternative
MaltaVehiclePIF and notified AIF
RegulatorMFSA
NotesLower cost base
Before you launch
What an investment fund in Luxembourg actually requires.What an investment fund in Luxembourg requires.
No product approval does not mean no requirements. The checklist below is what a compliant launch covers.
01
Legal form. Corporate, partnership or contractual vehicle chosen for the strategy and investors.
02
Authorised AIFM. A Luxembourg, EU or third-country AIFM authorised under the AIFMD, appointed under Article 4.
03
Minimum net assets - EUR 1,250,000 reached within twenty-four months of constitution.
04
Well-informed investors. Written adherence plus at least EUR 100,000, or assessment by a credit institution or investment firm.
05
Depositary. Appointed as required, with assets and cash monitoring arranged.
06
Administrator and auditor. Luxembourg service providers engaged before launch.
07
Constitutive documents. Articles or management regulations drafted for the strategy.
08
Issuing document. Including the Article 39 statement that the fund is not subject to Luxembourg supervisory authority supervision.
09
Compartments. Where an umbrella is used, ring-fencing and cross-liability addressed explicitly.
10
AIFMD compliance. Reporting, valuation, risk and liquidity management run through the AIFM.
11
Tax position. Subscription tax at 0.01% plus investor-level analysis in each relevant country.
01
Legal form chosen.
02
Authorised AIFM appointed.
03
EUR 1.25M in 24 months.
04
Well-informed investors.
05
Depositary appointed.
06
Administrator and auditor.
07
Constitutive documents.
08
Article 39 statement.
09
Compartments ring-fenced.
10
AIFMD reporting live.
11
Investor tax modelled.
Reflects the Law of 23 July 2016 on reserved alternative investment funds and the AIFM Law of 12 July 2013 as of 2026.Law of 23 July 2016 + AIFM Law 2013, 2026.
Verify it yourself
Official sources
Regulator pages, legal texts and public registers the figures on this page are based on.
- RegulatorCSSF - Authorisation of an AIFM under Articles 5 to 19 of the Law of 12 July 2013cssf.lu
- LawLaw of 23 July 2016 on reserved alternative investment funds (RAIF), consolidated version applicable from 28 July 2023 - Legilux (in French)legilux.public.lu
- LawLaw of 12 July 2013 on alternative investment fund managers, consolidated version applicable from 16 April 2026 - Legilux (in French)legilux.public.lu
- LawDirective 2011/61/EU on alternative investment fund managers (AIFMD), consolidated text of 16 April 2026 - EUR-Lexeur-lex.europa.eu
- RegisterLuxembourg Business Registers - List of reserved alternative investment funds (RAIF) kept by the RCS under Article 34 of the 2016 Law (in French)lbrcontent.public.lu
How it works
From first call to a live Luxembourg fund.
01
Strategy and vehicle
Assets, investors and distribution. Deciding RAIF or supervised fund and the legal form beneath it.RAIF or supervised.
02
The AIFM
An authorised AIFM appointed and the delegation of portfolio and risk management agreed.Appointed, delegated.
03
Providers and documents
Depositary, administrator and auditor engaged; constitutive and issuing documents drafted.Engaged and drafted.
04
Constitution
The fund constituted and registered. With the 24-month net asset target planned from day one.Registered, planned.
05
Operation
Subscriptions taken from well-informed investors, AIFMD reporting running, subscription tax paid.Subscriptions live.
Quick facts
VehicleRAIF
Law23 July 2016
Minimum net assetsEUR 1,250,000
Deadline24 months
ManagerAuthorised AIFM
Investor minimumEUR 100,000
Subscription tax0.01%
Product supervisionNone - disclosed per Art. 39
The Law requires the fund to state that it is not supervised by a Luxembourg supervisory authority. Sponsors who dislike that sentence should be using a SIF instead.
On the ground in Luxembourg
Run from our Luxembourg office.
Prifinance - Luxembourg
Luxembourg
Luxembourg
01
Vehicle and strategy
RAIF or supervised fund, legal form and compartment design decided against the actual strategy and investor base.Decided on facts.
02
The AIFM
An authorised manager appointed. Third-party or the sponsor's own. With the delegation model set out properly.Delegation set properly.
03
Service providers
Depositary, administrator and auditor selected and contracted before the fund is constituted.Contracted before launch.
04
Launch and compliance
Constitutive and issuing documents finalised, the 24-month asset target planned, AIFMD reporting live.24-month target planned.
We also have offices in
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
Dubai
UAE
33 Level, Al Saqr Business Tower
London
United Kingdom
7 Bell Yard
Madeira
Portugal
Rua da Alegria 31, 1F
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of Luxembourg funds.
One basis point at the fund level, and a full analysis at investor level, where it actually matters.
0.01% subscription tax
The annual charge set by Article 46 of the 2016 Law. One basis point, predictable and negligible against performance.Article 46.
Fund-level neutrality
The vehicle is designed to be tax-neutral so investors are taxed where they live rather than twice. The point of pooling.Taxed where you live.
Investor-level analysis
Each investor's home country determines their treatment; the fund documentation is built with that in mind.Home country decides.
Treaty access
Access depends on the legal form and the investor base. Modelled at structuring, not assumed.Form-dependent.
The manager layer
Where the sponsor also builds a Luxembourg management entity, its own taxation is planned alongside the fund.Planned alongside.
Substance and reporting
AIFMD reporting, DAC and CRS obligations apply. The structure is built to file, not to hide.AIFMD, DAC, CRS.
Tax summary
Subscription tax0.01% per annum
Fund levelNeutrality by design
Investor levelHome-country treatment
Treaty accessForm-dependent
ReportingAIFMD · DAC · CRS
*Figures per the Law of 23 July 2016 as of 2026. Investor-level outcomes are modelled with advisers in each relevant country.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Luxembourg vehicle, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live fund.
Follow Prifinance
Active across our channels.
Luxembourg · RAIF
Launch your investment fund in Luxembourg with expert support.
Full-service assistance - from vehicle choice and AIFM appointment to depositary, documentation and launch - run through our Luxembourg office.
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Request a free conclusion →FAQ
The Luxembourg fund - the questions we hear.
What is a RAIF?+
A reserved alternative investment fund under the Law of 23 July 2016 - a Luxembourg fund that is not subject to product supervision by a Luxembourg supervisory authority, because it must be managed by an authorised alternative investment fund manager who is.
What is the minimum size?+
Net assets of EUR 1,250,000, which must be reached within twenty-four months of the fund's constitution. It is a real deadline and we plan the capital raise around it from day one.
Who can invest?+
Well-informed investors. Under Article 2 that means either adhering in writing and investing at least EUR 100,000, or being assessed by a credit institution or investment firm as having the necessary expertise. RAIFs are not retail products.
Does the CSSF approve the fund?+
No. The RAIF operates on a registration model rather than pre-approval, and Article 39 requires the fund's documents to state that it is not subject to supervision by a Luxembourg supervisory authority. Supervision applies to the AIFM instead.
Do we need our own AIFM?+
You need an authorised one - either your own, if the sponsor builds and licenses a management company, or a third-party AIFM providing the service. The AIFM may be established in Luxembourg, elsewhere in the EU, or in a third country under the AIFMD.
What does the fund pay annually?+
Subscription tax at 0.01 per cent per annum under Article 46, plus the commercial costs of the AIFM, depositary, administrator and auditor, which are the real budget.
Can one fund run several strategies?+
Yes - umbrella structures with ring-fenced compartments are standard, letting strategies and investor groups sit in one vehicle without separate launches. Cross-liability is addressed explicitly in the documents.
RAIF or SIF?+
RAIF for speed where manager-level supervision satisfies investors; SIF where an institutional mandate or a distribution channel specifically requires a CSSF-supervised product. Investor requirements decide, and we ask them before choosing.
How long does a launch take?+
Months rather than years, driven by AIFM onboarding, service-provider contracting and documentation rather than by any approval queue. That is precisely the RAIF's advantage.
Who holds the licence: the fund or its manager?+
The manager. Article 4 of the 2016 Law requires the RAIF to be run by an authorised AIFM, and the CSSF supervises that manager rather than the fund. Firms that also want to advise clients or manage portfolios directly look at the CSSF investment firm route: see investment license in Luxembourg.
Why Prifinance for Luxembourg?+
Vehicle chosen against real investor requirements, AIFM and depositary selection run as a comparison, and the 24-month asset target treated as a plan rather than a footnote - from our Luxembourg office.
What is a RAIF?+
2016 Law fund, AIFM-managed.
Minimum size?+
EUR 1.25M in 24 months.
Who invests?+
Well-informed, EUR 100k.
CSSF approval?+
No - Art. 39 disclosed.
Own AIFM?+
Own or third-party.
Annual cost?+
0.01% + provider fees.
Compartments?+
Yes - ring-fenced.
RAIF or SIF?+
Investors decide.
How long?+
Months, not years.
Who holds the licence: the fund or its manager?+
The authorised AIFM. For client portfolios: investment license in Luxembourg.
Why you?+
Target planned, not noted.
Client notes
Google4.7★★★★★
Founders who wanted it done right.
Google4.7★★★★★
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of CSSF or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.