RAIF, SIF or SICAR in Luxembourg, which fund vehicle to choose?

The RAIF launches fast without direct CSSF authorisation (but with an authorised AIFM); the SIF and SICAR require CSSF authorisation, the SICAR being reserved for risk capital. All three target well-informed investors. The choice depends on strategy, timing and taxation.

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In short

The RAIF (law of 23 July 2016), the SIF (law of 13 February 2007) and the SICAR (law of 15 June 2004) are Luxembourg investment vehicles reserved for well-informed investors. They differ on authorisation, asset range, diversification requirement and tax treatment.

Key takeaway

  • RAIF: fastest to launch (no direct authorisation), but an authorised AIFM is mandatory.
  • SIF: broad asset range with diversification, under CSSF authorisation.
  • SICAR: dedicated to risk capital, no diversification requirement, specific tax regime.

Further reading: fund structuring in Luxembourg, special limited partnership form and AIFM and management company support.

RAIF vs SIF vs SICAR: comparison table

CriterionRAIFSIFSICAR
CSSF authorisation of the vehicleNo (authorised AIFM mandatory)YesYes
Assets / strategyAll asset typesAll types, diversifiedRisk capital (PE/VC)
Authorised AIFMMandatoryDepending on thresholdsDepending on thresholds
Risk diversificationYes (except risk-capital option)YesNot required
InvestorsWell-informedWell-informedWell-informed
Taxation0.01% subscription tax (specific regime if risk capital)0.01% subscription taxTaxable, but income from securities exempt; no subscription tax
Launch time6 to 10 weeksLonger (authorisation)Longer (authorisation)
Legal basisLaw of 23 July 2016Law of 13 February 2007Law of 15 June 2004

Sources: official texts cited on this page. Summary: Financial Services Luxembourg, licensed accountant.

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Official sources and verification

This page is published under the editorial responsibility of Mickaël LOC for Financial Services Luxembourg (business permit 10077274). The rules cited should be checked against competent authorities and the circumstances of the case.

Editorial version dated . Amounts and rates change with indexation and budget laws: check the date before relying on them.

FAQ

Frequently asked questions

Which vehicle for a Private Equity fund?

Often a RAIF (fast launch) or a SICAR (dedicated to risk capital), usually as an SCSp with a holding SOPARFI. The choice depends on timing, investors and taxation.

Does the RAIF need authorisation?

The vehicle itself has no direct CSSF authorisation, but it must be managed by a fully authorised AIFM: supervision is indirect.

Can a SICAR invest outside risk capital?

No: the SICAR is reserved for risk-capital investments. For a broader strategy, the SIF or RAIF are suitable.

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