Regulated Funds In Ireland Ucits Non Ucits

First for business. First for people.

Irelandthe domicile of choice for regulated funds

Move from lighter-regulated jurisdictions

The global fi nancial crisis has exposed a series of vulnerabilities in the global fi nancial system that need to be addressed in order to reaffi rm trust and confi dence within the investment management industry.

According to the PwC report “Transparency versus returns: The institutional investor view of alternative assets”, transparency and risk management were found to be as important as returns, to institutional investors in their evaluation of alternative asset managers. This report based on a global survey of 226 institutional investors and alternative investment providers was conducted by the Economist Intelligence Unit on behalf of PricewaterhouseCoopers in March 2008. The report also found when it came to listing the main criteria for choosing a third party provider , the quality of the compliance and risk management process and transparency ranked number two and three. In current environment we would expect that these criteria might now be ranked one and two.

Going forward, there will be a greater demand from investors and regulators for more transparent and highly regulated products. With this will be a move from the lighter-regulated jurisdictions to regulated jurisdictions such as Ireland. Particularly, in the current market, investors will take greater comfort in investing in products that offer the same complex trading strategies but operating within regulated structures in jurisdictions with strong regulatory reputations.

Since its inception as a centre for the domiciliation and servicing of investment funds, Ireland has positioned itself as a location for the establishment of “regulated” investment funds. As investors seek greater transparency and comfort from investment products and as greater regulatory oversight of investment funds looks imminent, Ireland has a number of well established suitable products to fi t this growing need and the experience and expertise to support them.

Introduction

Why choose Ireland as a domicile for your regulated funds? 1

Overview of the Irish Regulatory Environment 3

UCITS 5

Non – UCITS 9

Other Irish products & structures 13

Redomiciling a fund to Ireland 15

Taxation of Irish Funds 17

Promoters who have chosen Ireland – Top Ten 20

How PwC Ireland can help? 21

Appendix 1 23

Appendix 2 25

Ireland – a world leader Key facts

• Largest hedge fund administration centre in the world.(Ireland services an estimated EUR 799bn in HF assets as of Dec 2008, representing approximately 41% of global hedge fund assets, Source: Irish Funds Industry Association (IFIA) & HFM Week)

• Largest number of stock exchange listed investment funds. (1,605 investment funds (2,209 sub funds) listed as of December 2008, Source: Irish Stock Exchange (ISE))

• A leading European domicile for exchange traded funds.(Irish ETFs were valued at EUR 31.5bn as of October 2008, Source BGI Global Investors)

• Fastest growing European and UCITS fund administration centre over the past fi ve years.(Irish domiciled net assets grew by 49% between 2004-2008; the European average for the same period was 15%, Source: Central Bank of Ireland & EFAMA)

• A leading European domicile for money market funds.(EUR 330bn in Irish domiciled money market funds as of Feb 2009, Source: Central Bank of Ireland)

• A recognised EU and OECD, open and tax transparent jurisdiction with the lowest headline corporate tax rate in the OECD.

Ireland – a global hub for investment funds

• EUR 1.43 trillion in over 10,000 funds (EUR 652 bn in domiciled funds/EUR 776bn in non-domiciled funds) as at February 2009. (Source: Irish Funds Industry Association (IFIA))

• 353 fund promoters from over 50 countries have set up Irish domiciled funds which are distributed to shareholders in over 60 countries across Europe, the Americas, Asia and the Pacifi c, the Middle East and Africa. Including non domiciled assets, over 780 fund promoters use Ireland as a servicing centre for investment funds. (Source: Lipper Ireland Fund Encyclopedia 2008)

• Memoranda of Understanding: Ireland has entered into bilateral MoUs with China; Dubai; Hong Kong; Isle of Man; Jersey; South Africa; Switzerland and USA. A new MoU with Taiwan is under negotiation. Within the EU, Ireland cooperates with all relevant authorities on basis of the provisions of the European directives.

• Ireland is a mature funds market with 20 years of experience in dealing with a broad range of fund structures

• Increasing numbers of asset managers have located in Ireland in recent years, e.g. Pioneer Investments, Perpetual, Fideuram Bank in addition to indigenous asset managers such as Abbey Capital, BIAM, AIBIM and ILIM.

• Ireland also has a very large, well established offshore life industry.

Why choose Ireland as a domicile for your regulated funds?

Ireland - the domicile of choice for regulated funds 1 PricewaterhouseCoopers

Ireland - the domicile of choice for regulated funds PricewaterhouseCoopers 2

Reasons for choosing Ireland

• Innovation

– Market driven regulated product solutions

– First regulated jurisdiction to commit to alternative investment funds

– At the forefront of implementing UCITS product changes

– Speed to market for sophisticated products – 24 hour approval

– Flexible stock exchange listing options

– Development of asset/pension pooling solutions - Common Contractual Fund (CCF)

– Newly created Shariah funds specialist unit in the Financial Regulator

– Client focus, fl exibility and ‘can do’ attitude

• 12,000 skilled employees with availability of industry-wide training (over 9,500 employed directly by fund administrators and over 2,500 employed in associated services, e.g. legal, tax, audit, listing etc.)

• Constructive regulatory environment – robust and effi cient regulatory environment with a wide variety of investment fund vehicles available to suit individual investor needs. The Financial Regulator regulates on a ‘principled’ approach rather than on a rigid rules based system.

• Ireland is a member of the EU, Euro Zone, OECD and Financial Action Task Force and is continually ranked highly in international surveys of places to carry out business. Ireland is not included on any international list of tax havens (e.g. OECD/G20).

• Ireland is a modern, international, open economy where business can be conducted with Asia in the morning, the Americas in the afternoon and Europe throughout the day.

• Favourable political environment - Ireland has a pragmatic, business friendly government which is committed to maintaining the competitiveness of the Irish funds industry, e.g. the publication of ‘Building on Success’, the Irish Government’s strategic plan for the development of the international fi nancial services sector in Ireland. The Department of An Taoiseach’s IFSC Competitiveness Group reviews and reacts to competitiveness issues on an ongoing basis.

The Financial Regulator is the competent authority for the authorisation of regulated funds in Ireland. Their duties include:

• Approval of the fund promoter, investment manager and management company.

• Approval for the marketing of non-Irish investment funds into Ireland.

• Specifi cation and approval of the fund administrator and custodian.

• Specifi cation and approval of the prime broker in the case of hedge funds.

• Authorisation and ongoing supervision of Irish funds.

The regulatory authority in Ireland has continuously adopted an “open door” policy in their willingness to meet with project promoters and discuss issues directly with them. The Irish Financial Services Regulatory Authority (“the Financial Regulator”) is seen to be innovative and proactive to the needs of the Irish Funds Industry whilst maintaining a reputation as a fi rst-rate regulatory authority. One such example of this innovative behaviour can be seen with the enhancements to the Irish Qualifying Investor Fund (QIF), where the overall time for the authorisation of a QIF was reduced to 24 hours, on a fi ling basis only. A fast track approval process for fund promoters has also been introduced by the Financial Regulator. The Financial Regulator regulates on a ‘principles’ based approach rather than a rules based framework.

An Irish fund can be established as one of the following legal structures:

• Investment Company

• Unit Trust

• Common Contractual Fund

• Investment Limited Partnership

Irish funds are most commonly established as either investment companies or unit trusts.

The main service providers to an Irish fund are its administrator, custodian and investment manager. The investment manager can be based outside of Ireland but it is a requirement from the Financial Regulator that the administrator and the custodian must be based in Ireland.

The Irish custodian model as required by the Financial Regulator provides signifi cant comfort to investors as they specifi cally require the custodian to act in the interests of the unit holders in the funds. The custodian will be directly liable to the unit holders for any unjustifi able failure to perform its obligations or improper performance of them. Such duties will also extend to the custodian’s appointment of any sub-custodians, which is of particular importance to investors where assets are likely to be held in various jurisdictions outside Ireland.

There are two main fund regimes in Ireland; UCITS and Non-UCITS. There are a number of factors to take into consideration when deciding whether to structure an investment fund under either the UCITS or the Non-UCITS regime such as; location of target investors, investment policy of the fund etc.

The Non-UCITS regime is attractive to fund managers who wish to target sophisticated investors namely institutional and high net worth individuals. Additionally, certain funds which employ more complex investment strategies posing greater risk in return for potentially greater reward may not

Overview of the Irish Regulatory Environment


be permissible under the UCITS regime but can be set up as non-UCITS funds. The most popular fund structure under the non-UCITS regime is the Qualifying Investor Fund (QIF). The QIF is seen as a fl exible fund structure and has no investment restrictions.

On the other hand, the UCITS product is suited to managers who would like to distribute their funds to shareholders on a worldwide basis. The aim of the EU’s UCITS Directive was to create a pan-European funds market as part of the EU’s fi nancial services action plan, the objective of which, to allow for open-ended funds investing in transferable securities to be subject to the same regulation in every Member State. It was hoped that once such legislative uniformity was established throughout Europe, funds authorised in one Member State could be sold to the public in each Member State without the requirement for further authorisation, thereby furthering the EU’s goal of a single market for fi nancial services in Europe. This is commonly referred to as a “European Passport” and is available only to funds under the UCITS regime. Once a UCITS fund is approved in one EU country, application may be made to have the fund registered for marketing to the public in any other EU country.

Furthermore, the success of the UCITS brand has now transcended beyond the borders of the EU and the UCITS regime is now recognised globally as a well regulated investment product. 353 fund promoters from over 50 countries have set up Irish domiciled funds which are distributed to over 60 countries across Europe, Asia, the Americas, the Middle East and Africa.


A UCITS fund which must be open ended can avail of a “single passport” throughout the EU for the sale of its units/shares. This means that UCITS funds established in one member state of the EU can be sold to the public in all of the EU’s member states once the appropriate notifi cations have been made. They are the ideal vehicle for promoters who wish to distribute their funds throughout the EU without having to obtain authorisation from each Member State. The success of the UCITS structure has extended beyond the borders of the EU and the UCITS brand is now recognised globally as a well regulated investment product. UCITS funds are distributed heavily in Asia, the Middle East and South America as well as in Europe. There are now over 30,000 UCITS Funds in existence with assets, according to EFAMA’s Quarter 4 Statistical Release, in excess of €4.5trillion as at 31 December 2008.

UCITS

UCITS Profi le

Open/Closed Open ended

Legal Structures • Unit Trust


• Common Contractual Fund (CCF)

Samples of Investment Strategies under UCITS

• Fund of UCITS Funds

• Index Tracking Funds

• 130/30 Funds

• Exchange Traded Funds

• Capital Protected/ Guaranteed Funds

• Absolute Return Funds

• Target Return Funds

• Structured products within a UCITS wrappers

• Commodity Trading Advisor (CTA Structure)

Samples of Eligible investments for UCITS funds

• Transferable Securities*

• Money Market Instruments

• Cash Deposits

• Derivatives (swaps, options, futures and forwards –FDIs)

• OTC Derivatives

• Derivatives on commodity indices

• Derivatives on hedge fund indices

• Open ended funds/ closed ended funds in specifi c circumstances*

Not permissible under UCITS regime: – Direct investment in Commodities

– Physical short selling

Investor types/minimum subscription

• Retail

• No minimum subscription required


UCITS Profi le

Investment Restrictions • 5/10/40 rule; A UCITS fund may invest up to 10% of its assets in any one issuer. Where the fund invests more than 5% of its assets in any issuer the maximum amount of such holdings in excess of 5% is limited to 40% of the net asset value of the fund. The limit of 10% is raised to 25% in the case of bonds issued by an EU credit institution and subject by law to protect bond holders. If a UCITS invests more than 5% of its assets in these bonds issued by one issuer, the total value of this investment may not exceed 80%.

• May invest up to 35% of net assets in any one security issued by a government or public international body.

• May invest 100% of its assets in transferable securities and money market instruments issued by an EU member state, local authorities or governments of Australia, Canada, Japan, New Zealand, Norway, Switzerland, the U.S. or by certain supranational organisations.

• Risk exposure of a UCITS fund to a counterparty to an OTC derivative may not exceed 5% of net assets. This can be raised to 10% in cases where credit institutions are listed with EEA or other specifi c listed countries.

• Not more than 20% deposit with one credit institution.

• No more than 10% in unlisted securities.

• May only borrow on a temporary basis, limit is 10% of the net asset value of the fund.

• A UCITS fund may not invest more than 20% of its net assets in any one collective investment scheme and the schemes in which a UCITS fund invests must be UCITS or non-UCITS schemes with the essential characteristics of a UCITS. Furthermore, investment in non-UCITS may not, in aggregate, exceed 30% of net assets.

• UCITS are permitted to establish non- EU based subsidiaries subject to the Directors of the UCITS confi rming the establishment of the subsidiary complies with the UCITS Directive. Subsidiary structures in UCITS are subject to pre-clearance by the Financial Regulator and in addition to meeting the requirements of the Directive, the Financial Regulator has also imposed specifi c conditions relating to the operation and control of the subsidiary by the UCITS which are outlined in appendix two.

Approval Time Regulatory Approval Time:UCITS: 4 to 6 weeks Overall Establishment time:(including approval of service providers)UCITS – 3 months

* The full eligibility criteria and investment restrictions for UCITS are contained in the Financial Regulator’s UCITS notices, in particular UCITS 9 and 10. The Financial Regulator has clarifi ed that the above securities must comply with the eligibility criteria for Transferable Securities, specifi cally per the following: - negotiability, liquidity, valuation capability, risk profi le and complying with the investment objective or investment policy of the UCITS.


Distribution of Irish-domiciled UCITS Investment Funds in other EU Member States and beyond

UCITS funds established in Ireland can be sold to the public in all of the EU’s member states once the appropriate notifi cations have been made. The notifi cation procedures for each member state are defi ned by the UCITS Directive. There are differences from one country to another which often relate to specifi c local marketing arrangements. Irish UCITS must satisfy the local regulations relating to marketing and advertising in each country of distribution.

To market its shares/units in another EU Member State, an Irish UCITS must inform the Financial Regulator and the supervisory authority of the host country accordingly. It must simultaneously send to that supervisory authority:

• An attestation by the Financial Regulator to confi rm that it meets the conditions necessary to qualify as a UCITS.

• Its management regulations/articles of incorporation.

• Its prospectus/simplifi ed prospectus.

• Where appropriate, its latest annual report and any subsequent semi-annual report.

• Details of any arrangements made for marketing its shares/units in that other member state.

Ireland is renowned as a centre of excellence for UCITS products. According to the Irish Funds Industry Association (IFIA), 80% of Irish domiciled funds fall under the UCITS regime. Additionally, Ireland is the fastest growing European and UCITS fund administration centre over the past fi ve years. According to the Central Bank of Ireland and EFAMA, Irish domiciled net assets grew by 49% between 2004-2008; the European average for the same period was 15%. The chart below highlights the main countries of distribution for Irish UCITS funds.

Source: Lipper Hindsight – February 2009Note: Research is focused on fund groups in Ireland where the number of countries which they distribute to is greater than 10. (28 fund groups match this criteria)Other countries includes: Bahamas, Japan, Gibraltar, Isle of Man, Mauritius, Qatar, South Africa, United Arab Emirates & the US.EEA: European Economic Area - includes all EU member states, Iceland, Liechtenstein and Norway.

0 20 40 60 80 100

EEA

Other*

Taiwan

Switzerland

Singapore

Peru

Macau

Hong Kong

Chile

Channel Islands

Bahrain

Markets where Irish UCITS are registered

% Fund Groups


One of the main objectives of this proposal, is the introduction of the “full management company passport”, (“MCP”). The MCP seeks to allow a UCITS fund in one domicile to be managed by a Management Company located in another jurisdiction. Greater effi ciencies and cost savings will be gained by operating from one core centre. Under the new regime, Fund Managers will have the option to centralise their asset management, administration, risk management operations within one domicile.

Facilities must be available in the host Member State to meet redemption requests on the part of investors, to make payments to share/unit holders, and to provide them with all required information.

Irish UCITS distributing outside of the EU must satisfy the requirements of the individual countries, which varies from country to country. These should be investigated prior to the distribution of the fund.

UCITS IV - The future for UCITS

The next wave of UCITS is upon us, the UCITS IV proposal outlines new enhancements to the current regime. It proposes to remove ineffi ciencies and address administrative barriers within the current regime through the simplifi cation and improvement of the rules on notifi cation for marketing in other Member States. The proposal also plans to meet the demands of investment managers and retail investors by introducing formal procedures for fund mergers, introducing the UCITS master-feeder structure and replacing the Simplifi ed Prospectus with Key Investor Information. UCITS IV does not seek to alter the investments strategies or the scope of eligible investments under the current regime. The proposed enhancements seek to deliver a pan European product by way of improving fund distribution and creating cost effi ciencies.


Non–UCITS

The term Non-UCITS is generally used to describe all Irish authorised investment funds other that UCITS. These types of funds cannot “passport” throughout Europe. Non-UCITS are established under Irish law as opposed to EU law which is the case for UCITS. As a result the Irish Financial Regulator is allowed more fl exibility in its dealings with Non-UCITS funds. Non–UCITS funds have more fl exibility in investment strategy and borrowings than UCITS funds and can be used for a variety of fund structures/products.

Non-UCITS Profi le

Open/Closed Open ended

Legal Structures • Unit Trust


• Common Contractual Fund (CCF)

• Investment Limited Partnerships

Fund Structures • Retail Non-UCITS

• Professional Investor Fund (PIF)

• Qualifying Investor Fund (QIF)

Samples of Investment Strategies under the Non-UCITS regime

• Hedge Funds

• Fund of Hedge Funds

• Master Feeder Funds

• Venture Capital and Private Equity funds

• Property Funds

• Capital protected futures and options funds

• Leaveraged future and options

Investor types/minimum subscription

• Retail Non-UCITS (No minimum subscription)

• Professional investor(Minimum subscription - Euro125,000)

• Qualifying Investor(Minimum subscription - Euro 250,000 + wealth criteria)

Investment Restrictions

• Non-UCITS are subject to the Financial Regulator’s investment restrictions as contained in appendix one.

• All investment and borrowing restrictions which normally apply to Non-UCITS are automatically disapplied in the case of a QIF. As a general rule the Non-UCITS investment restrictions do not apply to the QIF. Therefore, a QIF can short sell, employ leverage and employ/invest in a wide variety of derivative contracts (i.e. swaps, Contract For Differences (CFDs), futures and options) and repurchase, reverse repurchase and stock-lending agreements.

• In the case of the PIF, general investment restrictions for Non-UCITS funds are usually doubled by way of derogation and agreed in advance with Financial Regulator.


Non-UCITS Profi le

Approval Time Regulatory Approval Time:QIF - 24 hours PIF - 4 weeksRetail Non-UCITS - 4 weeks

Overall Establishment time:(including approval of service providers)QIF - 4-6 weeks PIF - 6-8 weeksRetail Non-UCITS - 6-8 weeks

The Irish ‘Super QIF’

The Qualifying Investor Fund (QIF) is one of the most successful fund structures in Ireland today. QIFs are the vehicles which are most frequently used to structure alternative investment funds including hedge funds, funds of hedge funds, venture capital/private equity and real estate fund because of its fl exibility. The QIF is the mainstay of the Non-UCITS Irish domiciled product offering. Since the enhancements to the QIF structure by the Irish Financial Regulator in 2007, 395 QIFs (1,125 including sub-funds) have been approved. The main enhancement being that a QIF fund can now be authorised by the Irish Financial Regulator within 24 hours of the submission of relevant documentation to the Financial Regulator.


24 Hour authorisation – How does it work?

Since February 2007, the Financial Regulator now authorises a QIF on a fi ling-only basis. Therefore, QIFs can now be authorised by the Irish Financial Regulator within 24 hours of the submission of relevant documentation to the Financial Regulator provided the following pre-requisites are met:

• Service providers to the fund, including the promoter, investment manager, directors, trustee/custodian and administrator must be approved / cleared by the Financial Regulator in advance of the QIFs application for authorisation.

• Confi rmation must be supplied regarding compliance with the authorisation criteria.

An application must be fi led no later than 3pm on the day before the proposed date of authorisation.

Are there any investment restrictions?

There are no investment restrictions for a QIF.

• Where a QIF invests more than 50% of its assets in another scheme the QIF is regarded as a feeder type investment.

• QIFs established as fund of funds may invest up to 100% in unregulated schemes subject to a maximum of 50% in any one unregulated scheme.

• The Financial Regulator does not impose risk diversifi cation requirements. It is the responsibility of the directors of the investment company to ensure that the QIF complies with the legislative requirement.

• Debt securities - A QIF may not raise capital from the public through the issue of debt securities. However, the Financial Regulator does not object to the issue of notes by authorised collective investment schemes, on a private basis, to a lending institution to facilitate fi nancing arrangements. Details of the note issue should be clearly provided in the prospectus.

Who can invest in QIFs?

• High-net worth individuals or institutional investors.

• The investor must have a high degree of knowledge and experience in the relevant markets along with a detailed understanding of the investment risks involved.

• Investment in this type of fund is limited to:

(a) an individual with a minimum net worth (excluding main household and residence goods) in excess of €1,250,000 or

(b) an institution which owns/invests on a discretionary basis at least the equivalent of €25 million, although not necessarily in the Qualifi ed Investor Fund.

• Minimum initial subscription per investor in a QIF is €250,000, no limits made on subscriptions thereafter.

Are there any restrictions on borrowing or leverage?

A QIF is not subject to borrowing or leverage limits but the prospectus must specify the extent to which borrowing or leverage may be used.

Are there any restrictions on the use of a prime broker in relation to the QIF?

In the case of a QIF, there is no limit on the extent to which assets may be passed to the prime broker. The following is a summary of the Financial Regulator’s current position, for the use of prime brokers by Irish domiciled funds:

• The arrangement must incorporate a procedure to mark positions to market daily in order to monitor the value of assets passed to the prime broker on an ongoing basis.


• The prime broker must agree to return the same or equivalent assets to the fund.

• The arrangement must incorporate a legally enforceable right of set-off for the fund.

Where the prime broker holds assets of the fund greater than allowed above, it must be appointed as a sub-custodian by the fund’s custodian.

The prime broker must be regulated to provide prime broker services by a regulatory authority, must have a minimum credit rating of A1/P1 and must have shareholder’s funds in excess of €200 million (or its equivalent in another currency).

There must be clear disclosure in the fund’s documentation of its proposed relationship with the prime broker.

Are there any redemption restrictions?

While open-ended QIFs may provide for dealing on a quarterly basis, the Financial Regulator requires that the time between submission of a redemption request and payment of settlement proceeds must not exceed 90 calendar days. This period can however be extended to 95 calendar days in the context of a QIF feeder or fund of funds scheme, including a QIF which provides for dealing on a more frequent basis (e.g. monthly, weekly etc.) In such circumstances, a prominent statement highlighting the fact that while the scheme deals, for example, on a monthly basis there may be times when redemption proceeds are paid on a quarterly basis.

Are subsidiaries allowed with the QIF?

Property funds using the QIF structure may establish multiple layers of special purpose vehicles (“SPVs”). Certain other types of funds can also use “SPVs” subject to pre-clearance by the Financial Regulator.

How can the use of a SPV improve tax effi ciency?

Investors may invest funds in the QIF to effi ciently manage their assets while optimising the tax treatment. The QIF can hold such assets through an Irish Special Purpose Vehicle (SPV). The investment is made by the QIF in the SPV through a contribution of shares and debt. The SPV may use these funds to invest in a range of assets.

In practice, the SPV will not accumulate profi ts in its own right. While the SPV will be within Ireland’s securitisation regime and will be subject to Irish corporation tax at a rate of 25% on its taxable profi ts, transactions are generally structured so that the level of taxable profi t remaining is zero or negligible (subject to certain conditions). This is achieved by ensuring that the level of income of the vehicle is matched by tax deductible expenditure. The tax deductible expenditure includes funding costs and service fees as well as profi t-extraction payments such as interest on profi t participating debt and/or total return swap payments. As a tax exempt vehicle, the QIF will not suffer any Irish tax on interest income and dividends received from the SPV.

As a taxable vehicle, the SPV has access to Ireland’s treaty network resulting in lower or zero withholding taxes on investment returns.


The Common Contractual Fund- the Irish pooling tool

Common Contractual Funds (CCFs) were fi rst established in Ireland in 2003. It was created to enable pension funds and institutional funds to pool their investments in a tax effi cient manner. This new category of tax-exempt collective investment vehicle is constituted as a contractual co-ownership arrangement, rather than as a company or trust and as such, they are comparable to partnerships or FCPs from a legal perspective. They can be established as both UCITS and Non-UCITS funds.

An Irish CCF is available for investment by all investors other than natural persons. The tax transparency of the CCF makes it particularly suitable for pension pooling and it is also an excellent vehicle for asset pooling.

Pension pooling allows companies operating pension funds in several countries to ‘pool’ assets into a single pension pooling vehicle. The pension-pooling vehicle then invests in assets, such as global equities, bonds and cash, on behalf of the investing pension funds. Pooling offers considerable economies of scale, particularly for smaller pension funds, and this in turn leads to cost savings and enhanced returns. It also provides greater consistency in asset management and enhances control over risks.

In a nutshell, pension pooling is where the pension funds in various locations operate as normal but pool their assets in a specially designed funds structure.

Asset pooling is the same concept as pension pooling, except that the investors are not pension funds but rather institutions or other structures pooling their assets into a single fund vehicle.

CCFs are explicitly regarded as transparent for Irish tax purposes. The tax transparency is preserved so long as the investors are not individuals. Typically, investors include pension funds and other institutional investors. The expectation is that the investors in CCFs should in many cases be able to access the double tax agreements between their ‘home’ country and the countries in which the securities of the CCF are

located. Effectively, the CCF itself is expected to be ignored for treaty access purposes. This facilitates economies of scale in the management and administration of asset pools, as well as preserving the tax treaty benefi ts that may be available to institutional investors through direct investment.

These funds will continue to appeal to multi-national companies, which have pension schemes in a number of different countries for the benefi t of employees in those countries, as was the initial purpose of the vehicle. However, the tax and regulatory improvements ensure that the CCF has a broader appeal to fund promoters/institutions who want to effi ciently manage their assets while optimising the tax treatment.

Exchange Traded Funds

The Exchange-Traded Funds (“ETFs”) sector seems to have been less troubled by the recent global fi nancial crisis than many other sectors. Although assets are down as a result of falling markets, new ETF’s continue to be established. This is mainly to due to the fact that ETF’s have high transparency, low costs, high liquidity and high risk diversifi cation. They are also tax effi cient and require no minimum investment, other than the market price of one share. Exchange Traded Funds can be established as both UCITS and Non-UCITS funds.

Other Irish products & structures

Ireland 23%

Rest of Europe 77%

Ireland as a domicile for European ETFs

Total assets of European ETFs=Euro 100 BillionSource: Barclays Global Investors, September 2008


Ireland is a recognised key centre for the domiciliation and servicing of ETF products. It also has the added benefi t of being a tax effi cient location for ETFs. Aside from the usual tax exemptions applicable to investment funds and, by way of classifi cation and defi nition for tax purposes, Irish ETFs may avail of reduced withholding tax rates with the US under the Ireland/US tax treaty.

The majority of European ETFs are launched in Ireland. The availability of qualifi ed personnel and the time it takes to obtain regulatory approval for new products are important factors in this location choice. Additionally, Ireland has the experience and expertise in this area as it has been a leading European domicile for Exchange Traded Funds over the last number of years.

Money Market Funds

Money Market Funds are a type of mutual fund that provide investors with immediate availability of their money, while offering a return comparable with or better than some alternatives. These funds hold large quantities of short-term securities, some of which mature daily. Their purpose is to provide investors with a safe place to invest easily accessible cash-equivalent assets characterized as a low-risk, low-return investment. Money Market Fund investments are considered short-term, very liquid investments with a high credit quality.

Mutual fund trade groups, the Investment Company Institute and the International Investment Funds Association, recently released their latest quarterly ‘Worldwide Mutual Fund Assets and Flows’ survey. Ireland ranks second in money fund assets worldwide with its huge concentration of triple-A rated US dollar, euro and sterling ‘offshore’ MMFs domiciled in Dublin. Despite the recent market turmoil, Ireland continues to have a substantial money market fund presence. For the full table of results, see the chart below.

Source: Irish Financial Regulator

Source: Crane Data, ICI, IIFA

Irish Money Market Funds - Growth in Net Assets

350

300

250

200

150

100

50

0

01 02 03 04 05 06 07 08

Country Assets ($bils)

US 3441

Ireland 828

France 668

Luxembourg 477

Australia 199

Italy 90

Canada 68

Korea, Rep. of 54

Spain 52

Mexico 45

Switzerland 32

Germany 31

Japan 27

China 24

South Africa 24

World 4,446


Largest Money Market Mutual Fund Markets Worldwide

The requirements of the Irish Financial Regulator in relation to redomiciling a fund to Ireland are essentially the same as establishing a new fund. The main difference is that a scheme of amalgamation would need to take place i.e. amalgamating an offshore fund with an Irish fund. This entails going to the unit holders in order to get their vote in favour of an in specie transfer of the assets of the offshore fund to the Irish fund. Any proposal to amalgamate must obtain regulatory approval in advance of share holder notifi cation. Amalgamating an offshore fund with a new Irish fund can be done in a tax effi cient manner.

Merging or amalgamating with an Irish fund has many benefi ts as it allows fund promoters to manage a single pool of assets hence reducing the overall operating costs.

Requirements for amalgamating an existing offshore fund with an Irish fund

The minimum conditions that the Irish Financial Regulator requires for a fund amalgamation are as follows:

• In the case of a UCITS, the fund with which it is intended to merge must also be a UCITS.

• In the case of non-UCITS, the fund with which it is intended to merge must:

– be located in the State, another Member State of the European Union, a Member State of the European Economic Area (‘EEA’) (Norway, Liechtenstein, Iceland), Guernsey, Jersey or the Isle of Man;

– not contain restrictions on subscriptions or redemptions which are materially different to the non-UCITS, including the categories of target investors; and

– be authorised and supervised by the relevant competent authority.

Funds which market solely to qualifying, and in exceptional circumstances, professional investors may be permitted to amalgamate with funds located in other jurisdictions on a case-by-case basis. The Financial Regulator must be satisfi ed that all the requirements in

relation to the scheme of amalgamation are met and that the jurisdiction in question meets with their level of prudential supervision.

The fund amalgamation will only be effective if:

• It is approved by not less than three fourths of the votes cast, in person or by proxy, at the meeting;

• The votes in favour represent more than half of the total number of units in issue; and

• Provision is made to the effect that the Irish Collective Investment Scheme (CIS) will redeem holdings of all non-voting unit holders prior to the amalgamation.

In all cases, there must be full disclosure to unit holders of all material facts and considerations relevant to the proposed amalgamation by the promoter/management company.

The trustee of the Irish authorised fund must review and be satisfi ed with the proposed amalgamation and confi rm to the Financial Regulator in writing that it has no objection to the proposed amalgamation being put before unit holders for approval.

A general meeting must be held for all unit holders to consider the proposed amalgamation. All unit holders must be notifi ed of the outcome of the meeting. In the event that the amalgamation is agreed upon, unit holders must be advised of the procedures and deadlines by which they must submit their redemption requests, if they so wish.

Where the proposed amalgamation arises from a commercial decision on the part of the promoter/manager to rationalise its own activities/structures, they must agree to bear the costs of the amalgamation and arrangements for winding up of the relevant fund.

From the date of amalgamation, the investment manager must address the portfolio in advance to ensure compliance with the underlying investment policy of the non-UCITS fund.

Redomiciling a fund to Ireland


Amalgamation methods

There are two ways to amalgamate two funds:

Option One: the offshore fund transfers its assets to the Irish fund in exchange for units in the Irish fund

• As there is no actual exchange or disposal of units by the investors given that the investors remain invested in the offshore fund, the investors may avoid a taxable event (this will be subject to the investors’ local tax rules).

• The issue of units in an Irish fund in return for assets is exempt from Irish stamp duty.

• The transfer of assets to the Irish Fund may be subject to transfer taxes in Ireland and other jurisdictions (subject to any reliefs of that jurisdiction that may be available). It should be possible to structure the transaction to eliminate Irish stamp duty.

Option Two: a ‘paper for paper’ or ‘share for undertaking’ exchange whereby units in an offshore fund are exchanged for units in an Irish fund

• The difference with this option is that the investors receive replacement shares in an Irish fund in exchange for their shares in the offshore fund. The investors would not be subject to Irish tax in respect of income or gains on their units in the Irish fund, unless they were Irish resident investors.

• Transfer of assets in return for units is exempt from Irish stamp duty and from Irish VAT.

• In the case of fund amalgamations, arrangements are available for non Irish shareholders, who receive replacement shares in an Irish fund.

to avoid the obligation to make a non-resident declaration.

Post amalgamation

• The new merged fund can also rely on Ireland as a ‘one-stop-shop’ servicing of all types of instruments. Ireland has a well established attractive package for regulated funds. It has a highly reputable regulatory environment with a wide variety of investment fund vehicles available to suit individual investor needs. In addition to its fl exible, proactive regulatory environment, the Irish funds industry has a 10,000 strong workforce of skilled experts to service this ever expanding industry.

• Irish investment undertakings are tax exempt in respect of its income and gains derived from investments, Non Irish investors do not suffer any Irish withholding tax on income distributions or gains realised on redemptions of shares in the fund. In the case of Irish investors, withholding tax on distributions may apply at 25% (currently) and in respect of gains on redemptions/repurchases/disposals at the rate of 28% (currently).


Key Tax Benefi ts

• Irish regulated investment funds are exempt from tax on their income and gains irrespective of investors’ residency.

• No withholding taxes apply, under domestic legislation, on income distributions or redemption payments made by a fund to non Irish resident investors once an appropriate non resident declaration is in place.

• Irish collective investment funds are not obliged to charge VAT and most of the services provided to a fund are exempt from VAT, such as, management, distribution, custody/trustee, investment management, distribution and administration.

• Common Contractual Fund (CCF) – tax transparent vehicle - CCFs are explicitly regarded as transparent for Irish tax purposes. The expectation is that the investors in CCFs should in many cases be able to access the double tax agreements between their ‘home’ country and the countries in which the

Taxation of Irish Funds

Ireland is recognised for not having any banking secrecy or blockages with regard to the exchange of information unlike other offshore jurisdictions. It is the only international investment funds centre that is noted as having adopted the key taxation standards and principles of the OECD. This is mainly due to the fact that it has no banking secrecy and that it has fully implemented the EU Taxation of Savings Directive (EUSD), meaning that Ireland is not obliged to levy a withholding tax on the relevant interest payments as it applies the exchange of information regime. Withholding tax is applied in EU states that have yet to adopt this Directive.

securities of the CCF are located. Effectively, the CCF itself is expected to be ignored for treaty access purposes. This facilitates economies of scale in the management and administration of asset pools, as well as preserving the tax treaty benefi ts that may be available to institutional investors through direct investment.

• Corporate tax rate 12.5% – one of the lowest in Europe and hence very attractive for service providers, asset managers, distributors and other corporate entities. This highly attractive corporate tax rate, positions Ireland well in relation to UCITS IV pan-European management companies.

• No stamp duty or capital duty charges on the establishment of a collective investment fund.

• No ongoing ‘Net Assets’ taxes.

• Double Taxation Treaties: Ireland has fi fty tax agreements, which provide for the elimination or mitigation of double taxation with the following countries: Australia, Austria, Belgium, Bulgaria, Canada, Chile, China, Croatia, Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, India, Israel, Italy, Japan, Republic of Korea, Latvia, Lithuania, Macedonia, Luxembourg, Malaysia, Malta, Mexico, the Netherlands, New Zealand, Norway, Pakistan, Poland, Portugal, Romania, Russia, Slovak Republic, Slovenia, South Africa, Spain, Sweden, Switzerland, Turkey, United Kingdom, United States of America, Vietnam and Zambia. Planned new tax treaties: Albania, Azerbaijan, Bosnia Herzegovina, Moldova, Serbia, Thailand and a Protocol to the existing treaty with South Africa

• Irish domiciled funds have access to US tax treaty where fund is demonstrated to be trading – considerable advantage for Exchange Traded Funds.

• Based on experience, the Irish Vaiable Capital Company (VCC) has more benefi cial effective tax reclaim rates in continental Europe (Belgium, France, Germany and Italy) as well as in Australia, Japan and Korea.


Tax Exemption

To qualify for tax exemption in Ireland, a collective investment fund must take one of the following forms:

1, A unit trust authorised by the Unit Trusts Act 1990

2, A designated variable capital investment company

3, An investment limited partnership

4, A common contractual fund (CCF) not constituted as a UCITS fund

5, A non-designated variable capital investment company that is only available to ‘collective investors’ – defi ned as any investor investing money on behalf of as least 50 people and none of these persons own more than 5% of the moneys invested, for example a pension fund or life assurance company).

Taxation of a non-Irish resident Unitholder

No Irish tax arises on the happening of chargeable events where the investors are neither Irish resident/Irish ordinary resident and who have made the relevant declaration to that effect to the fund.

The tax declaration requires all non-Irish investors to declare that they are not Irish residents when they are applying for shares/units in a fund. Subsequent applications for shares/units in the same fund (or umbrella fund) or any other Irish domiciled fund promoted by the same fund promoter do not require a declaration to be made regarding an investor’s tax residence position (unless the investor’s non residence status has changed since the original declaration was made).

Taxation of an Irish Resident Unitholder

Irish resident investors may invest in Irish funds. The Irish fund is obliged to undertake tax reporting and deduct Irish tax on the happening of chargeable events where the investor is a non exempt Irish resident investor. Such tax returns need to be made every six months by the fund.

A chargeable event includes any distribution payments to Unitholders or any encashment, redemption, cancellation, transfer of units or appropriation or cancellation of a Unitholder by the fund for the purposes of meeting the amount of tax payable on a gain arising on a transfer.

A disposal is deemed to arise where shares have been held for eight years (and at each subsequent eight year anniversary), to the extent that the investor is a non exempt Irish resident/ Irish ordinary resident in Ireland. Any tax paid in respect of any deemed disposal is creditable against any tax payable on the ultimate disposal of the relevant fund investment.

A chargeable event does not include:

• An exchange by a Unitholder, effected by way of an arms length bargain where no payment is made to the Unitholder of Units in the fund for other units in the fund;

• Any transactions (which might otherwise be a chargeable event) in relation to units held in recognised clearing system as designated by order of the Irish Revenue Commissioners (e.g. units in an Exchange Trade Fund are normally held through clearing systems);

• A transfer by a Unitholder of the entitlement to a Unit where the transfer is between spouses and former spouses, subject to certain conditions; or

• An exchange of units arising on a qualifying amalgamation or reconstruction (within the meaning of Section 739H of the Taxes Act) of the fund with another investment undertaking.


Tax currently at the rate of 25% is required to be deducted by the fund from a distribution (where payments are made annually or at more frequent intervals) to an investor who is Irish resident/Irish ordinary resident. Similarly, tax currently at the rate of 28% must be deducted by the fund on any other distribution or gain arising to the investor on a disposal, redemption or transfer of shares by an investor who is non exempt Irish resident/Irish ordinary resident.

In general, the above tax is the full and fi nal liability for Irish individuals. In the case of institutional investors, the ultimate tax liability will depend on whether or not the investment return arises in respect of a trade. In the case of trading profi ts, the relevant tax rate is 12.5%, while the relevant company would be entitled to a credit for any tax deducted from any payment by the fund. In the case of non-trading companies, income distributions are ultimately subject to tax at 25%, while the 28% tax deducted by the fund in respect of gains on redemption is deemed to be the full and fi nal liability.

Where tax has not been deducted by the fund, any tax due by Irish investors is accounted for by the investor through the self assessment regime.

Tax Exemption for Certain Irish Investors

There are a number of Irish resident investors that are specifi cally excluded from this tax (i.e. 25% on distributions and 28% on gains arising on chargeable events). Declarations are also required to be made by the categories of exempt Irish Investors prior to the receipt of distributions or gains to ensure that no Irish tax is suffered on income distributions or gains made on redemption. Examples of exempt Irish investors include Irish pension funds, Irish life assurance companies and Irish charities.


Promoters who have chosen Ireland – Top Ten

Ireland Promoters

Domiciled Market Share Ranking by Assets as at 30 June 2008

Company Name Assets in US$Million Prior Year Assets in US$Million

1. Barclays 163,877 134,052

2. Goldman Sachs 99,910 81,905

3. HSBC 56,268 37,268

4. Russell Investments 48,492 53,824

5. Vanguard Group 39,219 36,648

6. Royal Bank of Scotland 39,048 12,609

7. Insight Investment 36,315 28,556

8. State Street 29,132 19,513

9. Blackrock Financial Management 27,979 16,837

10. PIMCO 25,763 21,313

Total Dublin Domiciled Fund 1,240,859 1,100,182

Source: Fitzrovia fi gures @ 30/06/08


Audit Services

Our audit approach is tailored to suit the size and nature of your organisation and draws upon our extensive industry knowledge. In addition to the independent audit, we offer advisory services in the areas of fi nancial reporting, corporate governance, regulatory compliance, independent controls and risk assessment.

Tax & Legal Services

Our Tax and Legal Services formulates effective strategies for optimising taxes, implementing innovative tax planning and effectively maintaining compliance.

In recognition of the international tax issues to be considered in structuring funds, our specialised tax team works extensively with our global investment management teams on an ongoing basis.

Regulatory Services

PwC has a dedicated regulatory and compliance service team to assist you with all aspects of fi nancial services regulation. The regulatory and compliance services team provides support and advice to help you identify, manage and control any existing and future regulatory risks. Our services can be broadly categorised under four main headings:

• Market entry; feasibility studies, authorisation services, governance arrangements, compliance frameworks, capital adequacy arrangements and notifi cation assistance

• Regulatory risk and compliance management

• Assistance with continuing regulatory obligations

• Responding to regulatory change

Advisory Services

PwC also provides a full range of business advisory services for both large organisations and independent advisors entering the investment fund business. Our business advisory services team can assist clients in making strategic assessments of the investment business, preparing business plans and economic analyses as well as advising on the structure of both the investment advisor and the underlying fund. The team can also offer advice on systems and operational needs, identifying and selecting outside vendors and preparation of full documentation of policies and procedures.

How PwC Ireland can help?

PwC55%

KPMG23%

E&Y17%

Deloitte4%Other

1%

PwC

KPMG

E&Y

Deloitte

Other


Our market shareIrish-combined (Irish and non-Irish domiciled) market share

Source: Funds Encyclopaedia June 2008

Appendices


Appendix 1

Non-UCITS investment restrictions

1, A fund may not invest more than 10 per cent of its net assets in securities which are not traded in or dealt on a market which is provided for in the trust deed, deed of constitution, articles of association or partnership agreement. Restrictions in respect of markets may be imposed by the Financial Regulator on a case by case basis.

2, A fund may invest no more than 10 per cent of its net assets in securities issued by the same institution. Where a fund has as a sole objective, investment in Irish equities, it may derogate from this limit as follows:

– An investment of up to 15 per cent of net assets may be made in an equity which has a weighting in excess of 10 per cent in the ISEQ index;

– An investment of up to 12.5 per cent of net assets may be made in an equity which has a weighting of between 8 per cent and 10 per cent in the ISEQ index.

3, No more than 10 per cent of the net assets of a scheme may be kept on deposit with any one institution; this limit is increased to 30 per cent for deposits with or securities evidencing deposits issued by or securities guaranteed by the following:

– a credit institution authorised in the European Economic Area (EEA) (European Union Member States, Norway, Iceland, Liechtenstein);

– a credit institution authorised within a signatory state, other than a Member State of the EEA, to the Basle Capital Convergence Agreement of July 1988 (Switzerland, Canada, Japan, United States);

– a credit institution authorised in Jersey, Guernsey, the Isle of Man, Australia or New Zealand;

– the trustee;

– a credit institution which is an associated or related company of the trustee, on a case-by-case basis.

4, In the case of an equity exchange index tracking scheme the limit of 10 per cent in point 2 may be increased to 20 per cent subject to the following conditions:

– The investment objective of the scheme must be to replicate a particular index. The weighting of securities of a specifi c issuer in the scheme’s portfolio must closely correspond to the weighting of those securities in the relevant index. Deviations should be temporary and related to operational diffi culties. Deviations in excess of 0.5 per cent of the net asset value of the scheme must be rectifi ed without delay;

– The index must be suffi ciently diversifi ed and represent an adequate benchmark for the market to which it refers;

– The index must be published and be freely available;

– The prospectus must clearly set out these conditions.

5, A fund may not hold more than 10 per cent of any class of security issued by any single issuer. This requirement does not apply to investments in other collective investment schemes of the open-ended type.

6, A fund may, subject to authorisation by the Financial Regulator, invest up to 100 per cent of its assets in transferable securities issued or guaranteed by any State, its constituent states, its local authorities, or public international bodies of which one or more States are members. Full disclosure must be made in the prospectus indicating the States, local authorities and public international bodies in the securities of which it is intended to invest more than 10 per cent of the assets in accordance with the provision of the preceding sentence.

7, A fund may acquire the units of other open-ended collective investment schemes subject to the following:

– a scheme may not invest more than 20 per cent of net assets in such schemes;

– a scheme may not invest more than 10 per cent of net assets in unregulated schemes1;

– where a scheme invests in units of a collective investment scheme managed by the same management company or by an associated or related company, the manager of the scheme in which the investment is being made must waive the preliminary/initial/redemption charge which it would normally charge;

– where a commission is received by the manager of the scheme by virtue of an investment in the units of another collective investment scheme, this commission must be paid into the property of the scheme.

8, The Financial Regulator may allow derogations from the limits laid down in this Notice to a scheme investing in other collective investment schemes or companies which are authorised or incorporated in a non- EU state and where such collective investment schemes or companies invest their assets in the securities of issuing bodies which have their registered offi ces in that state and where under the legislation of that state such a holding represents the most effective way in which the scheme can invest in the securities of that state.

9, A fund is permitted to engage, to a limited extent, in leverage through the use of techniques and instruments permitted for the purposes of effi cient portfolio management under the conditions contained in NU 16. The net maximum potential exposure created by such techniques and instruments or created through borrowing, under the conditions and within the limits contained in NU 3, or through both of these together, shall not exceed 25 per cent of the net asset value of a scheme. The prospectus must disclose a scheme’s intention to engage in leverage.

The above is by way of summary of the general investment restrictions that apply to Non-UCITS funds. For further reference see: http://www.fi nancialregulator.ie/industry-sectors/funds/non-ucits/Pages/default.aspx



Appendix 2

UCITS & Non-EU subsidiaries

The Financial Regulator’s recent clarifi cation now permits UCITS to establish non- EU based subsidiaries subject to the Directors of the UCITS confi rming the establishment of the subsidiary complies with the UCITS Directive and in particular, Article 25 (e); (shares held by an investment company or investment companies in the capital of subsidiary companies are only carrying on the business of management, advice or marketing in the country where the subsidiary is located, in regard to the repurchase of units at unit holders’ request exclusively on its or their behalf).

Subsidiary structures in UCITS are subject to pre-clearance by the Financial Regulator and in addition to meeting the requirements of the Directive, the Financial Regulator has also imposed specifi c conditions relating to the operation and control of the subsidiary by the UCITS as follows:-

• The subsidiary must be a private limited company. It cannot be a plc, collective investment scheme or an issuing body in its own right.

• The subsidiary must be wholly owned by the scheme.

• The directors of the scheme form a majority of the board of the subsidiary and must maintain full control over the activities of the subsidiary.

• The subsidiary must not appoint any entity directly.

• The prospectus must disclose; the name of the subsidiary and that the subsidiary is wholly owned by the scheme.

• The shares in each subsidiary must be registered in the name of the trustee.

• The underlying assets must be registered in the name of the trustee or in the name of the scheme or its subsidiary. The trustee must be appointed as trustee to each subsidiary and must be in position to demonstrate to the Financial Regulator that it has suffi cient controls in place in relation to each layer of the subsidiary structure.

• The assets of each subsidiary must be valued by the scheme or its delegate.

Source: Irish Financial Regulator’s website – http://www.fi nancialregulator.ie

PwC Investment Management Contacts - Ireland

Olwyn AlexanderTel: +353 1 792 8719Email: [email protected]

Pat CandonTel: +353 1 792 8538Email: [email protected]

Fiona De BurcaTel: +353 1 792 6786Email: fi [email protected]

Patricia JohnstonTel: +353 1 792 8814Email: [email protected]

Joanne KellyTel: +353 1 792 6774Email: [email protected]

Andrea KellyTel: +353 1 792 8540Email: [email protected]

Vincent McMahonTel: +353 1 792 6192Email: [email protected]

Damian NeylinTel: +353 1 792 6551Email: [email protected]

Jonathan O’ConnellTel: +353 1 792 8737Email: [email protected]

Marie O’ConnorTel: +353 1 792 6308Email: [email protected]

Ken Owens Tel: +353 1 792 8542 Email: [email protected]

Tony WeldonTel: +353 1 792 6309Email: [email protected]

Advisory

Andy O’CallaghanTel: +353 1 792 6247Email: [email protected]

Robin MenziesTel: +353 1 792 8553Email: [email protected]

Tax & Legal Services

Jim McDonnellTel: +353 1 792 6836Email: [email protected]

Pat WallTel: +353 1 792 8602Email: [email protected]

Pat ConveryTel: +353 1 792 8687Email: [email protected]

John O’LearyTel: +353 1 792 8659Email: [email protected]

Real Estate

Enda FaughnanTel: +353 1 792 6359Email: [email protected]

Regulatory and Compliance Services

Deirdre McManusTel: +353 1 792 7356Email: [email protected]


This publication has been prepared as a guide only. In the interests of brevity and clarity, detailed information may be omitted which may be directly relevant to an individual’s or an organisation’s circumstances. Professional advice should always be taken before acting on any information contained in this publication. Re-publication and dissemination (other than brief quotations with appropriate attribution) is expressly prohibited without prior written consent.

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Documents

Regulated Funds In Ireland Ucits Non Ucits