Choosing a structure: RAIF vs Cayman

Once the thesis is set, structure becomes a practical question: where do your LPs live, and where do your assets live.

For EMEA institutional capital, the Luxembourg RAIF is the workhorse. It is fast to launch — weeks not months — must be managed by an authorised AIFM, and can be passported across the EU under AIFMD. It carries the regulatory credibility that European pensions and insurers expect, without the heavier ManCo build-out of a SIF or Part II vehicle.

For US and offshore LPs, a Cayman feeder is standard. It plugs into the same master fund as the EU vehicle and gives US taxable, US tax-exempt and offshore investors the right tax-efficient route in. Most institutional raises end up as a master–feeder structure for exactly this reason.

Beneath the fund, the assets sit in local SPVs in the jurisdiction where they are located — a Luxembourg SCSp owning a German GmbH owning a German real-estate asset, for example. The SPV layer is what makes the debt financing work: lenders take their security at the SPV level, not at the fund level.

The rule of thumb: pick the wrapper that fits the LP base you can actually raise from, not the wrapper that sounds most impressive at conferences.