# Where to set up your fund: A comparative guide for fund managers ### Author: Josephine Koh ### Read time: 7 minutes ### Published date: August 20, 2024 Choosing the right jurisdiction depends on your fund's goals, investor base, and regulatory preferences. Here is a breakdown of six non-U.S./Europe regions favored by fund managers: For fund managers deciding where to establish funds outside the U.S. and Europe, the choice of jurisdiction is crucial. This guide provides a comparison of six locations: Cayman Islands, Abu Dhabi Global Market (ADGM), Dubai International Financial Centre (DIFC), Singapore, Australia, and Gujarat International Finance Tec-City (GIFT City). Each of these jurisdictions offers unique advantages: - Tax efficiency in the Cayman Islands - Strategic access to the Middle East in ADGM - Combination of regulatory robustness, tax efficiency, and dynamic investor base in DIFC - Robust investor base in Singapore - Established regulatory environment in Australia - Favorable regulatory and tax structures in GIFT City coupled with emerging market potential The table below summarizes the key attributes of each location: | **Location** | **Regulatory environment** | **Taxation** | **Reputation** | **Investor base** | | --- | --- | --- | --- | --- | | **Cayman Islands** | Flexible, clear, and business-friendly for investment funds | Tax-neutral status with no taxes on income, capital gains, or profits | Premier offshore financial center known for transparency and reliability | A global range of investors | | **Abu Dhabi Global Market (ADGM)** | Robust framework under English common law | Zero corporate and personal income tax for all investors | Growing reputation backed by UAE's commitment to financial stability | Mainly investors from the Middle East, particularly Gulf Cooperation Council (GCC) countries | | **Dubai International Financial Centre (DIFC)** | Transparent and reliable legal system based on English common law | 0% tax rate on profits, capital gains, and income for a renewable period of 50 years. No withholding taxes on dividends, interest, and royalties | Premier financial center known for strong regulatory framework, standards, and innovation | Diverse investor base, including sovereign wealth funds, institutional investors, family offices, and high-net-worth individuals from Middle East, Africa, and South Asia | | **Singapore** | Rigorous yet supportive framework by MAS (Monetary Authority of Singapore) | No capital gains or dividend income taxes from investments, with other tax incentives available | Known for political stability, strong legal system, and regulatory integrity | Global and diverse base of investors. | | **Australia** | Well-established framework overseen by ASIC (Australian Securities & Investments Commission) | Comprehensive tax regime with incentives, although complexities exist | Solid regulatory integrity and market sophistication | Broad spectrum including institutional investors and superannuation funds | | **Gujarat International Finance Tec-City (GIFT City)** | Special economic zone with a business-friendly regulatory framework | Favorable tax regime with exemptions and incentives | Emerging as a robust financial and IT services hub | Attracts domestic and international investors seeking opportunities in India and South Asia | ### Cayman Islands The Cayman Islands is a top destination for offshore investment funds, offering a flexible and business-friendly regulatory framework. Its legal system operates under English common law. The [Cayman Islands Monetary Authority (CIMA)](https://www.cima.ky/) ensures compliance with financial standards aligned with international [anti-money laundering](/content/learn/private-funds/regulations/aml-kyc/cayman-islands/index.html) (AML) and counter-terrorism financing regulations. #### Regulatory environment The Cayman Islands has a straightforward and flexible regulatory regime tailored specifically for investment funds, making it a favorite among global investors. #### Taxation One of the major draws of the Cayman Islands is its tax-neutral status. Funds domiciled here aren't subject to direct taxes on income, [capital gains](/content/learn/equity/stock-options/taxes/capital-gains/index.html), or profits. #### Reputation The Cayman Islands has a long-standing reputation as a premier offshore financial center, recognized for its transparency and reliability. #### Investor base Cayman Islands funds appeal to a diverse range of [institutional investors](/content/learn/private-funds/structures/institutional-investors/index.html), high-net-worth individuals, and family offices. ### Abu Dhabi Global Market (ADGM) ADGM, an international financial center in Abu Dhabi, United Arab Emirates, is gaining momentum as a leading investment hub. #### Regulatory environment ADGM operates under English common law and has a regulatory framework designed to ensure compliance with international financial standards. #### Taxation ADGM offers tax benefits, with zero corporate and personal income tax for entities operating within its jurisdiction. #### Reputation Although ADGM is relatively new compared to other financial centers, its reputation is growing, attracting international interest. #### Investor base ADGM provides access to investors in the Middle East and North Africa, particularly from Gulf Cooperation Council (GCC) countries. ### Dubai International Financial Centre (DIFC) Located in Dubai, UAE, DIFC is a leading financial hub with a robust legal and regulatory framework. #### Regulatory environment DIFC operates under a distinct legal system based on English common law, guaranteeing compliance with international standards. #### Taxation DIFC provides significant tax advantages, including a 0% tax rate on profits and no withholding taxes on dividends. #### Reputation DIFC has established itself as a premier financial center, recognized for regulatory excellence. #### Investor base DIFC offers access to a diverse investor base, including sovereign wealth funds and family offices from the MEASA region. ### Singapore Singapore is known for its stable regulatory environment and favorable tax regime. #### Regulatory environment Singapore's regulatory framework is rigorous yet supportive, ensuring compliance to protect investors. #### Taxation There is no capital gains tax on investment gains in Singapore, adding to its appeal. #### Reputation Singapore has earned a reputation for political stability and strong regulation. #### Investor base Singapore offers access to a global and diverse investor base, ideal for tapping into the Asia-Pacific market. ### Australia Australia maintains a well-established regulatory framework for fund management activities. #### Regulatory environment Australia's regulatory regime ensures investor protection and market integrity. #### Taxation While Australia has a comprehensive tax regime, complexities exist based on fund structure. #### Reputation Australia is known for its solid regulatory integrity and political stability. #### Investor base Australia attracts a diverse investor base, capitalizing on its large superannuation system. ### Gujarat International Finance Tec-City (GIFT City) GIFT City is emerging as a financial and IT services hub in India. #### Regulatory environment GIFT City operates under a special economic zone with its own simplified regulations. #### Taxation Entities in GIFT City enjoy various tax benefits, including exemptions from capital-gains tax. #### Reputation GIFT City is rapidly gaining recognition for its robust infrastructure and transparent regulatory practices. #### Investor base GIFT City appeals to a wide range of investors, attracting both domestic and international businesses.