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Funds and Specialized Structures

Purpose
Regulated fund vehicles for pooling investor capital in diversified portfolios managed by professional fund managers. CIS are open-ended funds allowing subscription and redemption, while CEFs have a fixed capital structure.

Permitted Activities
Investment in securities, real estate, private equity, hedge strategies, and alternative assets. Funds may be structured as Global, Specialized, or Professional CIS with varying investor eligibility requirements.

Taxation
CIS are tax-transparent — income is taxed at the investor level rather than the fund level. No withholding tax on distributions to non-resident investors. CEFs are subject to corporate tax at 15%.

Substance / Governance
Requires a licensed Fund Administrator (AIM), Custodian, and Investment Manager. Must have a minimum of 2 directors. Global funds require 3 local resident directors. Comprehensive governance framework required.

Reporting
Annual audited financial statements, NAV calculations, FSC regulatory returns, and periodic investor reporting including portfolio performance and risk disclosures.

Purpose
Each cell operates independently, providing ring-fenced protection for distinct assets or activities.

Permitted Activities
Insurance underwriting, captive insurance, asset holding, fund structuring, and segregated portfolio management. Ideal for multi-strategy funds and insurance-linked structures.

Taxation
Each cell is treated as a separate entity for tax purposes. Subject to standard corporate tax of 15%. May qualify for partial exemption depending on activities and substance.

Substance / Governance
Requires a licensed Management Company as administrator. Each cell must maintain separate accounting records. Directors must ensure cell-specific compliance and risk management.

Reporting
Separate audited financial statements for each cell and the core company, annual returns to the Registrar of Companies, and FSC regulatory reporting where applicable.

Purpose
An innovative fund structure with variable share capital that expands or contracts based on subscriptions and redemptions, providing flexibility for open-ended fund structures and umbrella fund arrangements.

Permitted Activities
Operating as an umbrella fund with multiple sub-funds, each with distinct investment strategies. Suitable for hedge funds, private equity, real estate, and mixed strategy funds.

Taxation
Tax-transparent structure where income is attributed to investors rather than the VCC itself. Each sub-fund may have specific tax treatment based on its activities and investor base.

Governance
Requires licensed fund administration, custody arrangements, and independent directors. Must comply with the VCC Act and FSC fund governance guidelines. Robust risk management across sub-funds is essential.

Reporting
Consolidated and sub-fund specific audited financial statements, NAV calculations, FSC regulatory returns, and comprehensive investor reporting./p>