ARTICLE
22 December 2025

Global Fund Structuring: Cayman And The UAE In Perspective

SH
Stuarts Law

Contributor

Stuarts is a leading offshore law firm in the Cayman Islands specialising in investment funds and offering fully integrated corporate and commercial advice from a team of experienced, award-winning attorneys. Whether it's navigating the complexities of Fintech, cryptoassets, real estate, investment funds, M&A's, regulatory, banking, company incorporation, dispute resolution, immigration, or any other business challenge, Stuarts have the expertise and experience to guide you toward success. At Stuarts, our team are known for world-class responsiveness, efficiency, and cost-effectiveness; working closely with clients from around the world to solve their most complex business challenges, transactions and obligations. Our proven track record in advising leading international law firms, investment managers, investment companies and high-net-worth individuals is a result of the deep understanding of our markets and our clients’ needs.
The Cayman Islands continues to hold its position as the leading global domicile for investment funds. This reputation is built on consistent regulatory clarity...
Worldwide Finance and Banking

The Cayman Islands continues to hold its position as the leading global domicile for investment funds. This reputation is built on consistent regulatory clarity, structural flexibility, international recognition, and an ecosystem that has matured around the needs of the alternative investment industry. Recent market analysis, including 2025 industry reports, reinforces that Cayman remains the default choice for global fund sponsors seeking efficiency, predictability, and investor confidence.

Fund managers often focus on three core priorities when selecting a jurisdiction: tax neutrality, investor familiarity, and speed to market. Cayman excels in each of these areas. Investors worldwide already understand how Cayman structures operate, which reduces friction when raising capital. Service providers, regulators, and legal frameworks in Cayman work together in a way that creates a smooth path from formation to launch, even for complex strategies or cross border structures.

Tax neutrality is another defining feature. Cayman vehicles do not attract local income tax, capital gains tax, or withholding tax. This allows investors to participate without taking on additional layers of jurisdictional taxation. The jurisdiction also offers a wide range of vehicles such as exempted companies, limited partnerships, and segregated portfolio companies, which allows structuring to be tailored precisely to the needs of investors and managers. These features continue to make Cayman attractive for open ended funds, closed ended funds, digital asset strategies, and hybrid structures that need both flexibility and legal certainty.

The depth of Cayman's professional ecosystem remains unmatched among international domiciles. The jurisdiction benefits from a sophisticated legal sector, highly experienced administrators, global auditors, and independent directors who understand institutional governance expectations. Regulatory oversight by the Cayman Islands Monetary Authority is regarded by investors as stable, proportionate, and aligned with international standards. This ecosystem helps give allocators and financial institutions the confidence that Cayman structures will be properly managed throughout their lifecycle.

Cayman's ability to adapt to new market trends also contributes to its leadership. Industry data shows that fund structures launched in 2024 and 2025 increasingly include liquidity features that align with investor demand, as well as growing exposure to digital assets and tokenised products. The jurisdiction continues to refine its regulatory and legal frameworks to support these innovations while maintaining the level of investor protection expected in global markets.

To illustrate Cayman's position, it is helpful to compare it with another commonly considered fund jurisdiction. Below is a worked example comparing Cayman to the United Arab Emirates, particularly for managers who raise capital from Middle East investors or explore ADGM or DIFC structures.

Comparison Example: Cayman Islands vs United Arab Emirates

Feature Cayman Islands United Arab Emirates
Global investor recognition

Very high. Cayman is the default for hedge funds, private equity structures, and cross border capital raising.

Moderate. Recognition is improving, but many global LPs still view the UAE as a regional domicile rather than a global one.

Tax and fiscal environment

Fully tax neutral for funds and investors. No local corporate income tax, capital gains tax, or withholding tax for investment funds.

Tax incentives exist within ADGM and DIFC, but the UAE has a broader corporate tax regime and more complexity around tax documentation, substance, and reporting.

Fund structuring flexibility

Multiple vehicle types with long established legal precedent. Standard for open ended and closed ended funds marketed to global investors.

Good flexibility, but structures are newer, less tested, and often viewed as more suitable for regional managers or feeder arrangements.

Regulatory and service provider depth

Mature and globally trusted ecosystem. International administrators, auditors, and directors are fully integrated into the Cayman market.

Growing ecosystem, but many managers still rely on service providers located outside the UAE due to less depth locally.

Global distribution and acceptance

Widely accepted across the USA, Europe, Asia, and Latin America. Very few investors require additional explanation or diligence.

Strong regional acceptance. Outside the Middle East, investor comfort varies and may require additional diligence.

This comparison highlights a common conclusion. The UAE is an appealing jurisdiction for regional strategies, certain specialist structures, or managers marketing primarily to Middle East investors. Cayman, on the other hand, remains the stronger choice for managers seeking global scale, flexible structuring, and broad investor acceptance across multiple continents.

When choosing a domicile, sponsors should consider their investor base, investment strategy, desired liquidity profile, and long term scaling plans. For funds marketed to multiple regions or institutional allocators, Cayman's track record, regulatory stability, and entrenched ecosystem continue to provide a clear advantage. For innovation focused strategies, including digital asset funds and tokenised structures, Cayman has demonstrated a willingness to evolve without sacrificing legal certainty or investor protection.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

[View Source]

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More