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Gibraltar Funds

The document describes three types of Gibraltar private funds structured as a limited company, limited partnership, or limited partnership with an LLP manager. It provides details on the legal structure, taxation implications, and service providers for each fund type.
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0% found this document useful (0 votes)
66 views9 pages

Gibraltar Funds

The document describes three types of Gibraltar private funds structured as a limited company, limited partnership, or limited partnership with an LLP manager. It provides details on the legal structure, taxation implications, and service providers for each fund type.
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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A B A C U S 2024

Gibraltar Fund Types


ABACUS 2024

Expert Wealth 
Management &
Financial Solutions
W W W. A B A C US . G I
Gibraltar Private Fund
Fund: Limited Company
Manager: Limited Company

Investors subscribe to the fund via non-


I N V ESTO RS
FU N D P RO M OTE RS / M A N A G E RS voting, participation shares. Maximum
( S H A RE H O LD E RS )
of 50 offers available to investors.

Shareholders / Directors

G IB FUND LTD Tax: the company will need to file a tax


return but should not suffer tax: no CGT
G I B M A N - C O LT D
and exemption to tax on investment
BANK ACCOUNT income.

MGT & PERFORMANCE FEES

Holds voting “ordinary shares” of the Fund FUND


I NVESTM E NTS
Service Providers
Corporate Investment Director of the Fund (fund is self-managed)
Can also participate in Fund by investing via participating shares F U N D A D M I N I S T R ATO R : A B A C U S
Taxability of fee income dependent on where management S E C R E TA RY & R E G O F F I C E : A B A C U S
& control is effective from. If deemed to be Gibraltar,
taxable at 12.5% LEG A L A DVIS O RS
Can add Gibraltar resident directors, if so required B AN KE RS
Can remit dividends upwards to shareholders (no WHT) A U D I T O R S ( V O L U N TA RY )
C USTO D I A N S / E X C H A N G ES , E TC

W W W. A B A C US . G I
Gibraltar Private Fund
Fund: Limited Partnership
Manager: Limited Company

Investors subscribe to the fund via


I N V ESTO RS partnership interests / capital account.
FU N D P RO M OTE RS / M A N A G E RS ( L I M I T E D P A RT N E R S ) Maximum of 50 offers available to
investors.

Shareholders / Directors

G IB FUND LTD Tax: “Look-through” entity - no tax


G I B G P LT D (LOOK-THROUG H) should be levied on the Fund itself;
( G E N E R A L P A RT N E R ) instead Partners will need to assess their
individual tax situation.
BANK ACCOUNT

MGT & PERFORMANCE FEES

FUND
Service Providers
Acts as the corporate General Partner (controller) of the Fund
I NVESTM E NTS
Taxability of fee income dependent on where management F U N D A D M I N I S T R ATO R : A B A C U S
& control is effective from. If deemed to be Gibraltar,
taxable at 12.5% S E C R E TA RY & R E G O F F I C E : A B A C U S
Can add Gibraltar resident directors, if so required LEG A L A DVIS O RS
Can remit dividends upwards to shareholders (no WHT)
B AN KE RS
A U D I T O R S ( V O L U N TA RY )
C USTO D I A N S / E X C H A N G ES , E TC

W W W. A B A C US . G I
Gibraltar Private Fund
Fund: Limited Partnership
Manager: Limited Liability Partnership

Investors subscribe to the fund via


I N V ESTO RS partnership interests / capital account.
FU N D P RO M OTE RS / M A N A G E RS ( L I M I T E D P A RT N E R S ) Maximum of 50 offers available to
investors.

Limited Partners

G IB FUND LP Tax: “Look-through” entity - no tax


GIB GP LLP (LOOK-THROUG H) should be levied on the Fund itself;
( G E N E R A L P A RT N E R ) instead Partners will need to assess their
individual tax situation.
BANK ACCOUNT

MGT & PERFORMANCE FEES

FUND
Service Providers
Acts as the corporate General Partner (controller) of the Fund
I NVESTM E NTS
Also “look-through” for tax purposes: taxability of fee income F U N D A D M I N I S T R ATO R : A B A C U S
passes through to the partners within the LLP
S E C R E TA RY & R E G O F F I C E : A B A C U S
LEG A L A DVIS O RS
B AN KE RS
A U D I T O R S ( V O L U N TA RY )
C USTO D I A N S / E X C H A N G ES , E TC

W W W. A B A C US . G I
Gibraltar Experienced Investor Fund (Standalone)
Fund: Limited Company
Manager: Limited Company

Investors subscribe to the fund via


participating shares. Need to qualify as
I N V ESTO RS
FU N D P RO M OTE RS / M A N A G E RS Experienced Investors per EIF regulations
( S H A RE H O LD E RS )
(typically investing over €100k) but
unlimited number allowed.

Shareholders / Directors

E I F D I R EC TO RS
G IB EIF LTD
G I B M A N - C O LT D Tax: the company will need to file a tax
BANK ACCOUNT return but should not suffer tax: no CGT
and exemption to tax on investment
income.
MGT & PERFORMANCE FEES

Holds voting “ordinary shares” of the Fund


FUND
I NVESTM E NTS
Service Providers
Corporate Investment Director of the Fund (fund is self-managed)
Can also participate in Fund by investing via participating shares F U N D A D M I N I S T R ATO R : A B A C U S
Taxability of fee income dependent on where management S E C R E TA RY & R E G O F F I C E : A B A C U S
& control is effective from. If deemed to be Gibraltar,
taxable at 12.5% LEG A L A DVIS O RS
Can add Gibraltar resident directors, if so required B AN KE RS ( REQ U I RE D )
Can remit dividends upwards to shareholders (no WHT) AU D I TO RS ( R EQ U I R E D )
E I F D I R EC TO RS ( 2 R EQ U I R E D )
C USTO D I A N S / E X C H A N G ES , E TC

W W W. A B A C US . G I
Gibraltar Experienced Investor Fund (Standalone)
Fund: Limited Partnership
Manager: Limited Company

Investors subscribe to the fund via


partnership interests/capital account.
I N V ESTO RS
FU N D P RO M OTE RS / M A N A G E RS Need to qualify as Experienced Investors
( L I M I T E D P A RT N E R S )
per EIF regulations (typically investing over
€100k) but unlimited number allowed.

E I F D I R EC TO RS Shareholders / Directors

G IB EIF LP Tax: “Look-through” entity - no tax


G I B G P LT D (LOOK-THROUG H) should be levied on the Fund itself;
( G E N E R A L P A RT N E R ) instead Partners will need to assess their
BANK ACCOUNT individual tax situation.

MGT & PERFORMANCE FEES

Service Providers
FUND
Acts as the corporate General Partner (controller) of the Fund F U N D A D M I N I S T R ATO R : A B A C U S
I NVESTM E NTS
Taxability of fee income dependent on where management
& control is effective from. If deemed to be Gibraltar, S E C R E TA RY & R E G O F F I C E : A B A C U S
taxable at 12.5% LEG A L A DVIS O RS
Can add Gibraltar resident directors, if so required
B AN KE RS ( REQ U I RE D )
Can remit dividends upwards to shareholders (no WHT)
AU D I TO RS ( R EQ U I R E D )
E I F D I R EC TO RS ( 2 R EQ U I R E D )
C USTO D I A N S / E X C H A N G ES , E TC

W W W. A B A C US . G I
Gibraltar Experienced Investor Fund (PCC)
Fund: Protected Cell Company
Manager: Limited Company

Investors subscribe to the fund via participating


I N V ESTO RS shares. Need to qualify as Experienced Investors
FU N D P RO M OTE RS / per EIF regulations (typically investing over €100k)
MANA G E RS but unlimited number allowed. Investors can
select which cells to subscribe to.
CELL 1 CELL 2 CELL 3

Shareholders /
Directors
G IB EIF PCC LTD E I F D I R EC TO RS

CELL 1 CELL 2 CELL 3


G I B M A N - C O LT D BANK ACCT BANK ACCT BANK ACCT Tax: the company will need to file a tax
return but should not suffer tax: no CGT
and exemption to tax on investment
income.

MGT & PERFORMANCE FEES

CELL 1 CELL 2 CELL 3 Service Providers


Holds voting “ordinary shares” of the Fund F U N D A D M I N I S T R ATO R : A B A C U S
Corporate Investment Director of the Fund (fund is Assets and liabilities of
self-managed) S E C R E TA RY & R E G O F F I C E : A B A C U S
I NVESTM E NTS each cell (or sub-fund)
Can also participate in Fund by investing via participating are ringfenced and legally LEG A L A DVIS O RS
shares
segregated from other cells B AN KE RS ( REQ U I RE D )
Taxability of fee income dependent on where management
& control is effective from. If deemed to be Gibraltar, AU D I TO RS ( R EQ U I R E D )
taxable at 12.5%
E I F D I R EC TO RS ( 2 R EQ U I R E D )
Can add Gibraltar resident directors, if so required
Can remit dividends upwards to shareholders (no WHT) C USTO D I A N S / E X C H A N G ES , E TC

W W W. A B A C US . G I
Gibraltar Experienced Investor Fund (PC LP)
Fund: Protected Cell Limited Partnership
Manager: Limited Company

Investors subscribe to the fund via partnership


I N V ESTO RS interests / capital account. Need to qualify as
FU N D P RO M OTE RS / Experienced Investors per EIF regulations (typically
MANA G E RS investing over €100k) but unlimited number allowed.
Investors can select which cells to subscribe to.
CELL 1 CELL 2 CELL 3

Shareholders /
E I F D I R EC TO RS
Directors
G IB EIF PC LP
(LOOK-THROUG H)
Tax: “Look-through” entity - no tax
G I B G P LT D should be levied on the Fund itself;
( G E N E R A L P A RT N E R ) CELL 1 CELL 2 CELL 3 instead Partners will need to assess their
BANK ACCT BANK ACCT BANK ACCT individual tax situation.

MGT & PERFORMANCE FEES

CELL 1 CELL 2 CELL 3 Service Providers


Acts as the corporate General Partner (controller) of F U N D A D M I N I S T R ATO R : A B A C U S
the Fund
Assets and liabilities of S E C R E TA RY & R E G O F F I C E : A B A C U S
Taxability of fee income dependent on where management
& control is effective from. If deemed to be Gibraltar, I NVESTM E NTS each cell (or sub-fund)
are ringfenced and legally LEG A L A DVIS O RS
taxable at 12.5%
segregated from other cells B AN KE RS ( REQ U I RE D )
EIF directors are appointed to the corporate GP
Can remit dividends upwards to shareholders (no WHT) AU D I TO RS ( R EQ U I R E D )
E I F D I R EC TO RS ( 2 R EQ U I R E D )
C USTO D I A N S / E X C H A N G ES , E TC

W W W. A B A C US . G I
Contact us T RU ST E D TO D E L I V E R VA LU E

Julian Kerrianne Daniel Joanne


Pitaluga Cortes Pitaluga Rodriguez

Gibraltar
5-9 Main Street,
Gibraltar,
GX11 1AA
T: +350 20078777
E: contactus@abacus.gi

W W W. A B A C U S . G I

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