QIAIFs benefit from the following features and Irish domicile infrastructure:
- QIAIFs are available in 5 different legal structures; the two corporate structures (the ICAV and the VCC), unit trusts, investment limited partnerships (ILPs) and common contractual funds (CCFs)
- QIAIFs are not subject to Irish tax on income or gains and no Irish withholding taxes on redemption payments or dividends, provided certain straightforward conditions are adhered to
- very few investment restrictions, the principal ones being those imposed by AIFMD on certain private equity type strategies and on investments in securitisations and certain Central Bank of Ireland imposed restrictions
- no borrowing or leverage restrictions (other than for loan origination funds)
- fast-track, 24 hour regulatory approval process
- internally (self)-managed, own AIFM, external AIFM and platform models all available;
- listing readily available on the Irish Stock Exchange, if desired
- significant service provider infrastructure in Ireland, with 47 fund administrators and 18 depositories)
- capacity to migrate offshore funds from a number of domiciles to Ireland as QIAIFs, via a reasonably efficient process, avoiding any asset realisation
QIAIFs can be established as single, stand-alone funds or (save for ILPs) as umbrella funds with one or more sub-funds. Investment and borrowing limits apply at sub-fund level as each sub-fund is treated from a regulatory perspective as a separate QIAIF. It is not currently possible to have an umbrella ILP.
Within an umbrella, it is possible to have sub-funds with different liquidity profiles – open ended, open-ended with limited liquidity or closed-ended – and one sub-fund can invest in another sub-fund of the same umbrella. Segregated liability between sub-funds within an umbrella exists either under statute (for ICAVs and for investment companies), or under trust law (unit trusts) or can be imposed contractually (CCFs).
Certain additional prospectus disclosure and constitutional documentation provisions are required for umbrellas, principally relating to segregation of assets/liabilities of one sub-fund from the others.