🇰🇾Investment Fund Domicile: Jurisdiction, Structure and Launch

The fund's jurisdiction determines the law under which the fund itself exists: the powers of the manager, investors' rights to distributions and redemptions, the grounds and limits of asset segregation, and the liquidation procedure. What is registered is a specific product—a partnership, a corporate fund with variable capital, a unit trust, or a sub-fund of an umbrella structure—in one of the statutory categories: private fund, AIF, UCITS, QIAIF, RAIF, VCC, LPF, QIF, PIF.

The fund's domicile does not coincide with the manager's licence and does not in itself confer the right to offer interests to investors. A Cayman fund may be managed by a UK company, a Luxembourg RAIF must appoint an external authorised AIFM, and a Singapore VCC only works with a manager meeting local law requirements. Where the investment team is located and on what basis it manages assets is the subject of a separate article on the management company; the legal basis for offering interests to investors in each specific country is the subject of the article on cross-border fund distribution; the overall map of private funds is collected in the funds hub.

This page proceeds from product to jurisdiction: the legal form and what it actually segregates; the dependence of the regime on assets and the liquidity promised to investors; tax qualification for each group of investors; and only after that—a comparison of specific domiciles in the US, the Caribbean, the Channel Islands, Europe, Asia and the Gulf, the cost of mandatory service providers and the time to first closing.

What the fund domicile determines

The choice of jurisdiction breaks down into four independent decisions, which in ready-made proposals are usually mixed into one:

1. Applicable law—which law determines the powers of the general partner or board of directors, investors' rights, the procedure for distributions and the consequences of default on obligations.
2. Legal form—partnership, company with variable or fixed capital, trust, contractual fund, umbrella structure with sub-funds, company with segregated portfolios, series.
3. Product regime—the statutory category to which the fund belongs and the associated restrictions on investors, assets, leverage and liquidity.
4. Intensity of supervision—notification, registration, supervision through a licensed manager or direct approval of the fund by the regulator.

Within one country these decisions are combined very differently. A Luxembourg RAIF is launched without prior approval by the CSSF for each fund, while a UCITS from the same jurisdiction goes through a full procedure and is subject to detailed rules on eligible assets and diversification. In the Cayman Islands, open-ended funds are regulated by the Mutual Funds Act, closed-ended funds by the Private Funds Act, and these are different obligations for valuation, custody of assets and reporting. A Delaware partnership does not in itself constitute a regulated fund: federal exemptions and rules for offering interests are checked separately.

Three levels of construction operate under their own rules and almost never reduce to one country.

Separately determined are the tax residence of the fund and the manager, the jurisdictions of companies holding assets and the carried interest regime. Coincidence of all levels in one country is justified only when the team, investors or assets are actually located there.

Legal forms and what each segregates

For the partnership shell, the seven-way LP comparison compares legal personality, public registers, tax treatment, the regulatory gate and inbound migration. It covers the SCSp, Delaware LP, Cayman ELP, Irish ILP, Hong Kong LPF, Jersey LP and English PFLP. Use that comparison for the legal form and the matrix below for the domicile and product regime.

The fund's form resolves a single question: between whom and what does the legal boundary run. Everything else is derivative of this choice.

Classes of interests regulate fees, currency, hedging rules, voting rights, liquidity terms and distributions. They almost never protect the assets of one portfolio from the creditors of another. When different portfolios, different managers or different groups of creditors are needed, a sub-fund, segregated portfolio, parallel fund or separate legal entity is required.

A standalone fund is easier to show to an anchor investor as a separate management system and easier to transfer to another manager. An umbrella structure reduces the marginal cost of each subsequent product, but creates a common board of directors, a common set of providers and a common reputation. Savings appear when there are actually several sub-funds; one sub-fund under an expensive umbrella shell costs more than a standalone fund.

Assets, liquidity and product regime

Strategy determines both the permissible form and the volume of regulation. Identically named "alternative funds" are subject to different rules depending on what exactly they buy.

Purchasing an existing loan and originating a new loan are different activities. Participation in a syndicated loan usually remains an investment, whereas finding a borrower, agreeing terms, origination, servicing and enforcement may trigger lending regimes, consumer credit, banking activity and local rate restrictions. From 16 April 2026, credit funds in the EU are additionally subject to the rules of Directive (EU) 2024/927: retention of 5 per cent of the nominal value of each originated loan, leverage limit of 175 per cent for open-ended and 300 per cent for closed-ended credit funds, prohibition on an originate-to-distribute model.

The liquidity promised to investors must match the liquidity of the assets. A closed-ended fund with staged capital contributions is appropriate where exit depends on the sale of a private asset. An open-ended product requires observable pricing, settlement, cash management, redemption restrictions, suspension rights, segregated positions for illiquid assets and stress testing. An evergreen private markets fund only works with an honest mechanism between incoming, outgoing and remaining investors: valuation lag, redemption queue and excess cash balance are not hidden by marketing wording.

Tax qualification of the fund

Tax transparency determines who is recognised as the recipient of income—the fund itself or its investors. In a transparent structure, income is attributed directly to investors, sometimes regardless of actual distribution. In an opaque structure, the fund is considered an independent taxpayer, and the investor is taxed on distribution of profit or sale of an interest.

Legal form does not provide an answer. One country recognises a partnership as transparent, another as a separate taxpayer, and hybrid qualifications are also encountered. Therefore, the regime is checked three times: under the law of the fund's country, under the law of each significant investor group and under the law of the countries where the assets are located. The result determines access to tax treaties, withholding at source, application of CFC, PFIC, ECI and UBTI rules, the procedure for accounting for losses and the volume of reporting.

There is no universal "international feeder". US taxable investors, US tax-exempt organisations, foreign investors in US assets, EU institutional investors, individuals and family offices, insurers, sovereign funds, charities, employees of the manager and investors requiring sharia compliance are analysed separately. Differences in fees, currency and redemption terms are formalised by classes of interests. When the taxpayer, the obligation to file returns, the permissible composition of assets or the legal basis for placement changes, a feeder fund, blocker company, parallel fund or AIV is needed.

Each of the four instruments solves its own problem.

• A feeder fund collects capital from one group of investors and directs it to the master fund, preserving the tax wrapper appropriate for that group.
• A blocker company changes the qualification of income and separates investors from ECI, UBTI or the obligation to file local returns; it does not eliminate the tax itself.
• A parallel fund invests simultaneously with the master under an agreed policy, but holds its own portfolio.
• An AIV is created for a specific deal when it is necessary to isolate jurisdictional, licensing or tax risk.

Each such entity means separate audit, administration, banking, FATCA and CRS obligations, directors and reconciliation of operations.

The right to benefits under tax treaties is checked by tax residence, beneficial owner status, limitation on benefits provisions, principal purpose test, anti-hybrid rules and substance. A registered office and nominee board of directors are not sufficient for this.

USA: Delaware and federal exemptions

Delaware remains the standard for US private funds. The usual construction is a fund in the form of a limited partnership, a separate LLC for the general partner, a management or advisory company and a structure for receiving carried interest. The partnership agreement sets out in detail the obligations of investors, capital requirements, distribution procedure, powers of the investor advisory committee, consequences of key person departure, removal of the manager and transfer of interests; the mechanics of the agreement itself are analysed in the materials on LPA and capital calls.

Registration in Delaware does not exempt from the federal regime. The SEC considers the fund, the manager and capital raising separately: a private fund relies on the 3(c)(1) or 3(c)(7) exemption of the Investment Company Act, and offers interests under Rule 506(b), Rule 506(c) or Regulation S.

The 3(c)(1) exemption limits the circle to beneficial owners—no more than one hundred, or no more than two hundred and fifty for a qualifying venture capital fund with aggregate contributions up to $12 million—and does not permit public offering.

The 3(c)(7) exemption removes the limit on the number of owners, but only admits qualified purchasers: for an individual this is investments of at least $5 million. An accredited investor under Regulation D and a qualified purchaser for 3(c)(7) are different statuses, and confusion of these thresholds in practice is more common than errors in the structure itself.

A Series LLC suits platforms working deal-by-deal, but the segregation of series, their fate in bankruptcy, the willingness of the bank and custodian and tax accounting are checked for each series separately: details in the article on Delaware Series LLC, and the typical fund construction in the article on Delaware LP. For foreign investors and US tax-exempt organisations, a Cayman feeder or blocker company is usually added to the Delaware fund, but only after calculating ECI, UBTI and the full cost of additional entities.

Common law domiciles: Cayman Islands, BVI, Jersey, Guernsey

Cayman Islands

The main international domicile for hedge funds, master-feeder structures, direct investments and private credit. Forms: exempted limited partnership for closed-ended strategies with staged capital contributions, exempted company for corporate and open-ended funds, unit trust for part of Asian and institutional capital, segregated portfolio company for multiple portfolios.

Classification determines obligations. Open-ended funds, where the investor has the right to demand redemption, fall under the Mutual Funds Act; closed-ended pools under the Private Funds Act. CIMA guidance separates categories by specific features: a registered fund under section 4(3) requires a minimum initial investment of CI$80,000 per investor, a fund with a limited number of investors under section 4(4) admits no more than fifteen investors, the majority of whom have the right to appoint and remove the fund operator, and a private fund under the Private Funds Act requires no minimum investment at all. The registration fee for a private fund is CI$4,125 plus CI$300 for filing the application, and to this are added annual audit by an approved local auditor, independent valuation, cash monitoring and verification of title to assets.

A Cayman fund does not have a European passport: offering interests in the EU, UK, Singapore and Hong Kong requires an independent basis. Tax neutrality at the fund level does not create entitlement to benefits under tax treaties in respect of portfolio assets. Details in Cayman fund.

British Virgin Islands

BVI offers calibrated categories for small and emerging managers: alongside private fund and professional fund for open-ended strategies and the private investment fund regime for closed-ended, two concessionary regimes operate for those starting out. BVI FSC guidance separates them by number of investors, fund size and duration of approval.

Both concessionary regimes cease to be suitable as soon as the strategy, assets or number of investors exceed the limits, so the path of conversion to a professional fund is laid down at launch, not after exceeding the threshold. Review of the category in offshore incubator funds.

Jersey

Jersey Private Fund—a simplified regime for professional and other eligible investors: since 6 August 2025 (JPF Order 2025) the former cap of fifty offers and investors has been removed—the offer is addressed to a restricted group of professional and eligible investors—the application is submitted through a local designated service provider, JFSC consent with a full set of documents is issued by fast-track procedure within 24 hours, and listing of the fund's interests is permitted with JFSC consent. The current edition of the JPF Guide clarified key practical matters: investor compliance is assessed at the time of admission and is preserved upon subsequent change of status, in the case of forced transfer of an interest the acquirer must independently meet the criteria, and the fund's governing body is expected to have at least one director resident in Jersey. The fund may be established as a company, partnership, unit trust or cell structure.

Guernsey

The Private Investment Fund regime provides several routes with different intensity of requirements: through a designated manager, through qualified private investor status and through family connection between investors. Applications meeting GFSC requirements are considered on a fast-track basis; companies, partnerships, trusts and cell structures are permitted. There is no European passport, so placement under AIFMD and UK financial promotion rules are analysed separately, and the cost of service providers is compared with Jersey, BVI and the Cayman Islands.

Europe: AIFMD II, RAIF, QIAIF and ELTIF

From 16 April 2026, Member States apply Directive (EU) 2024/927, which revised AIFMD: rules on delegation of functions, requirements for disclosure of fees and expenses, mandatory set of liquidity management tools for open-ended funds and a separate regime for credit funds. Requirements are the same in all Member States and increase the permanent burden on the manager regardless of the country chosen.

Luxembourg

The law of 23 July 2016 on RAIF removes prior approval of each fund by the CSSF, but requires an external authorised AIFM (Article 4) and leaves the fund within the AIFMD regime. The circle of investors is limited to well-informed: institutional and professional investors or persons who have confirmed their status in writing and invested at least 100,000 euros or received confirmation of competence from a bank, investment firm or AIFM. Minimum net assets are 1,250,000 euros, to be reached within 24 months of establishment. Subscription tax is 0.01 per cent per annum of net assets, and the risk diversification requirement is removed only for a RAIF investing exclusively in venture capital (Article 48).

In addition to RAIF, Luxembourg offers SIF under direct CSSF supervision, SICAR for venture capital, Part II UCI as a regulated product outside the UCITS regime and UCITS itself. Cost is formed by AIFM, depositary, central administrator, conducting officers, audit and regulatory fees, so a small first fund makes sense only on someone else's licensed platform. Details in Luxembourg funds and SCSp.

Ireland

English-language EU platform with the largest market for administration and depositary services. Central Bank of Ireland supervises alternative funds and their managers. A Qualifying Investor AIF is aimed at qualified investors and requires a minimum initial subscription of 100,000 euros; with a full set of documents, authorisation is issued on a fast-track basis. The fund is structured as an ICAV—a corporate form created specifically for investment funds—or as an investment company, unit trust, Common Contractual Fund or Investment Limited Partnership. A Retail Investor AIF admits a wider circle of investors at the cost of product restrictions and closer scrutiny.

ELTIF and United Kingdom

European Long-Term Investment Fund—the only European regime allowing long-term illiquid assets to be offered by passport including to retail investors. Revised rules have been in force since 10 January 2024, technical standards for them were published in October 2024; the fund requires an authorised AIFM and approval under product rules, and CSSF describes procedures for the fund and the manager separately.

The United Kingdom after leaving the EU has no passport. Private Fund Limited Partnership serves UK direct and venture capital funds, Long-Term Asset Fund—an authorised regime for illiquid assets with enhanced valuation and liquidity control requirements, investment trust provides permanent capital and exchange liquidity instead of redemption at net asset value. Raising capital in the EEA requires European AIFM and fund or analysis of national private placement regimes; in the opposite direction the FCA notification regime operates.

Malta offers authorised AIF, notified NAIF, as well as PIF and NPIF for professional and private capital; Cyprus—authorised AIF and registered RAIF under external AIFM, with a minimum of 500,000 euros of assets to be reached within 24 months and 125,000 euros per well-informed investor.

Liechtenstein sits inside the EEA without being in the EU, so an AIF under the AIFMG carries the same European passport through a licensed AIFM while the jurisdiction keeps the Swiss franc and its own supervisor. The FMA registers a small AIFM for CHF 10,000 and licenses a full AIFM for CHF 20,000; a new AIF is launched on the manager's notification rather than by product approval, and for marketing the FMA must respond to the AIFM within 20 working days. The fund takes the form of a contractual investment fund, a collective trust, a SICAV or SICAF, or an investment limited partnership; a Liechtenstein-licensed depositary is mandatory, income from the managed assets of the AIF is exempt and there is no withholding tax on distributions and no subscription tax. Retail investors are admitted only with a KIID and leverage capped at three times net asset value. In practice this is the cheaper end of the same passport that Luxembourg and Ireland sell, and it competes with Malta rather than with them.

Germany keeps its alternative funds in a separate box: a Spezial-AIF under the KAGB is not product-approved at all — the investment conditions are filed with BaFin under section 273 and marketing is notified — but it is closed to retail money. Alongside professional investors it admits semi-professional ones, defined by a commitment of at least 200,000 euros, a written risk acknowledgement separate from the commitment itself and an assessment of the investor's expertise by the AIFM. A depositary is mandatory, and the vehicle is a Sondervermögen, an investment limited partnership or an investment stock corporation.

Swiss L-QIF is available only to qualified investors and does without FINMA product approval, since supervision goes through the management or administration organisation. In the Netherlands, from 1 January 2025, a reform of the tax qualification of legal forms is in force: the "open" CV regime has been abolished, the definition of FGR has been narrowed, and the former presumptions of transparency from old templates no longer apply.

Asia and the Gulf: VCC, LPF, OFC, ADGM and DIFC

Singapore

Variable Capital Company—a corporate fund form operating as a standalone or umbrella fund with statutorily segregated sub-funds; each sub-fund is registered and taxed separately. A VCC must appoint directors, a corporate secretary, an auditor and a manager meeting Singapore law requirements. One-off ACRA fees on registration break down as follows.

The VCC itself does not provide a manager's licence, approval for offering interests by MAS, or automatic tax exemption. Notification of a scheme with a restricted circle of investors is submitted through the MAS collective investment schemes register and does not mean verification of product quality. Tax regimes Section 13O and 13U have their own criteria for assets under management, local expenses and number of investment professionals; launch practice is described in the article on private fund in Singapore.

Hong Kong

Limited Partnership Fund has existed since 31 August 2020 under a separate ordinance. Companies Registry confirms that an LPF has no separate legal personality and operates through the general partner, investment manager and authorised representative. Registration does not replace SFC product approval or Type 9 licence for asset management; Type 1 and Type 4 licences may be required for placement and advisory. Open-ended Fund Company—a corporate fund with variable capital under SFC supervision, public or private, with the possibility of sub-funds; this form is more natural for liquid strategies.

International investors often prefer the familiar Cayman shell, and the Hong Kong LPF holds mainland China and Greater Bay Area assets or admits local investors. Then deal allocation, expenses and taxation of both structures are agreed in advance.

ADGM and DIFC

Both financial zones operate under English common law and distinguish public fund, exempt fund for professional clients and qualified investor fund with increased minimum investment and proportionate regulation. In ADGM, a fund may be an investment company, limited partnership or cell structure; FSRA forms provide for separate procedures for manager, fund, marketing and foreign manager. DFSA in DIFC admits an external manager if its home regulation is acceptable and local conditions are met. Both zones remain financial free zones: marketing in the mainland UAE requires separate analysis.

Service providers, cost and time to first closing

The cost of a fund is set by mandatory providers; the registration fee is almost invisible in this sum. A depositary is required for European AIFs and UCITS and costs more than a simple custodian. An administrator calculates net asset value, maintains the investor register and services capital calls; its willingness to work with a specific strategy is checked before fund establishment, not after. An auditor in a number of jurisdictions must be local and approved by the regulator—in the Cayman Islands this is a direct requirement. Directors, MLRO, registered office and corporate secretary add permanent expenses regardless of asset volume.

Time to first closing is determined by the slowest element. Partnership registration takes days, AIFM authorisation takes months, opening bank and custodial accounts for a fund with digital assets or an exotic portfolio sometimes takes longer than all the rest combined. A ready-made shell only speeds up registration: it does not resolve issues of form suitability, lawful basis for placement and operational readiness.

First closing is possible when the fund is established and registered, the manager has the right to act, contracts with providers are signed, accounts are open and working, documents have passed review by the anchor investor, and the capital call and valuation procedure is described and reproducible. A step-by-step breakdown of launch is in the ultimate guide to fund formation.

Typical mistakes

Scenarios

First venture fund in the US

Team from San Francisco, investors predominantly American, target size $60 million. Delaware LP, 3(c)(1) exemption with a limit of one hundred beneficial owners, placement under Rule 506(b), manager operates as exempt reporting adviser.

Key risk: the appearance of foreign or US tax-exempt investors requires a Cayman feeder or blocker company, and the decision is made before first closing.

Credit fund for EU investors

Direct lending strategy to mid-market businesses, investors are European insurers and pension funds. Luxembourg RAIF in SCSp form under external authorised AIFM, minimum net assets 1,250,000 euros within 24 months.

Key risk: from 16 April 2026, retention of 5 per cent on each loan and leverage limit of 300 per cent for closed-ended credit fund apply.

Asian family office platform

Several families, different strategies, common management system. Singapore umbrella VCC with segregated sub-funds, manager under Singapore regime, application for Section 13U tax regime.

Key risk: VCC registration does not provide a manager's licence or tax exemption—both statuses are confirmed independently and before launch.

Domicile matrix: sixteen regimes side by side

The country sections above describe each domicile on its own terms. The two tables below put them on one axis so that the launch decision can be read across regimes rather than sequentially. The first table covers regulator, speed, investor floor, mandatory providers and distribution; the second covers published fees, tax at fund level, redomiciliation and standing on the EU and FATF lists. Every row is a specific statutory route, not a country in general: the same jurisdiction offers slower and faster products, and the fast ones carry investor restrictions.

The second table holds the money and the exit. Published regulator tariffs are cited where the regulator publishes them; service-provider budgets are not, because they are quoted per mandate and not by a tariff.

What the matrix actually decides

Three readings come out of the tables, and none of them is about the headline tax rate.

Speed and the investor floor move together. The fastest routes — JPF consent in 24 hours, a Guernsey PIF registered in one business day, a DIFC QIF in about two days, an Irish QIAIF authorised in 24 hours — are all closed to anyone below a professional or qualifying-investor standard, and three of them require a local gatekeeper to file (a Jersey designated service provider, an authorised AIFM, a licensed fund manager in the zone). Where the regulator steps back, someone licensed stands in its place. A regime with no gatekeeper and no investor floor does not exist in this table.

Published tariffs are the smallest line and the only comparable one. Annual regulator fees cluster between about £1,000 in Guernsey and 8,800 euros for a Luxembourg umbrella; a Cayman fund pays CI$4,125 plus CI$525 per segregated portfolio; an Irish umbrella pays the levy from 8,734 euros plus 579 per sub-fund. Against that, the mandatory providers are an order of magnitude larger and are not published anywhere: a European AIF must appoint a depositary, a central administrator and an approved auditor, while a Cayman private fund needs a local approved auditor but no depositary, and a BVI incubator or approved fund needs neither an audit nor, in the incubator's case, an administrator. That single structural difference, not the fee schedule, explains most of the gap in year-one cost between a RAIF and a BVI approved fund.

The passport is the only thing money cannot buy afterwards. Luxembourg, Ireland, Malta, Cyprus and Germany carry the AIFMD passport through the manager; Liechtenstein carries the EEA passport on the same logic; Cayman, BVI, the Channel Islands, Switzerland, Singapore, Hong Kong, ADGM and DIFC carry none. A fund that discovers European investors after launch has to build a European feeder or run national private placement regimes country by country, and that retrofit costs more than the difference in launch fees ever saved. Conversely, an EEA passport is dead weight for a fund whose investors are all in Asia or the Gulf.

Worked example: the same $30m fund in three domiciles

A first closed-ended fund of $30 million with a five-investor professional base, one strategy and no European money. Published regulator cost in year one: a BVI approved fund pays $1,800 on application and $1,200 a year to renew, with no audit and no depositary; a Cayman private fund pays CI$300 to file plus CI$4,125 a year and must appoint a local approved auditor; a Luxembourg RAIF pays no CSSF product fee at all, and then appoints an authorised AIFM, a depositary, a central administrator and an approved auditor, and raises 1.25 million euros of net assets within 24 months while paying subscription tax of 0.01% a year.

On published tariffs the three look within a few thousand of each other. On the mandatory-provider line they do not: the RAIF's four appointments are the reason this fund size is normally launched on someone else's licensed platform rather than on its own RAIF, and the reason the same $30 million goes to the Caribbean or the Channel Islands when the investors are not European. The tariff table answers a question nobody is really asking; the provider column answers the real one.

Cell and series structures compared

An umbrella, a cell and a series all promise the same thing — several pools of assets under one legal shell, with the creditors of one pool kept away from the others. They deliver it with very different legal force. The question that separates them is not the fee per cell but whether the segregation is recognised by the court of the asset's country and by the forum in an insolvency, and whether the counterparty contracts with the cell or with the shell.

The practical ranking is short. An incorporated cell behaves almost like a separate company and is the only form that reliably answers a lender or custodian asking who exactly is its counterparty. A statutory compartment or protected cell — Luxembourg, Ireland, Singapore, the Channel Islands, Malta, ADGM, Cayman — segregates strongly at home, which is why the operative work is at the contracting stage: every agreement, account and security document must name the cell and state that the company acts for its account. A Delaware series is the cheapest and the least portable: it was built for platforms whose assets, banks and counterparties are all in the United States, and a registered series exists mainly so that a secured lender has something to perfect against.

A share class does none of this. Classes divide fees, currency, hedging and distribution rights inside one pool of assets; a derivative counterparty of class A can as a rule reach the assets attributed to class B unless the law of the fund's country establishes segregation. Where different pools of creditors, different managers or different liquidity architectures are needed, the answer is a sub-fund, a cell, a parallel fund or a separate entity — the mechanics of each form are set out in the articles on Delaware Series LLC, Maltese cell companies, the Singapore VCC and the Cayman fund.

Choosing by profile

The same matrix reads differently for each type of sponsor, because each profile has a different binding constraint: the investor base for venture, the holding period for private equity, the prime broker for hedge, the tax award for a family fund, and custody for digital assets.

Two cross-cutting points survive every profile. The concessionary regimes are entry products with a ceiling written into them — twenty investors and $20 million for a BVI incubator, two years plus a twelve-month extension — so the conversion path is part of the launch plan. And redomiciliation is not a universal exit: Cayman, the BVI, the Channel Islands, Malta and Cyprus allow continuation both ways, a Singapore VCC and a Hong Kong OFC or LPF take a foreign fund in but offer no route out, and for Liechtenstein, Switzerland and Germany no statutory fund migration route is published at all. A domicile chosen on the assumption that the fund can simply move later may turn out to be a one-way door.