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When it comes to cross-border fund structuring, conversations with tax advisers continue to be dominated by one overriding theme: the pace of change and how structuring is adapting to meet shifting investor and manager needs.
This change is multifaceted.
Private markets are evolving structurally – not just growing, with new fund structures such as evergreen funds, semi-permanent structures and hybrid/open-ended models coming to the fore. As a result, managers want structures that can accommodate long-term strategies and investor liquidity needs.
In tandem, fund financing creative capital raising and liquidity solutions are also now core to the ecosystem.
Meanwhile, the retailisation of the private markets is accelerating, with private equity and alternatives moving into semi-liquid and retail channels and wealth platforms becoming major distribution channels. Institutional and retail capital now regularly sit alongside each other, putting an emphasis on transparency and good governance.
In addition, the tokenisation of real-world assets is revolutionising the funds landscape, breaking down barriers for investors and giving them improved liquidity, transparency and control over their allocations – total tokenised market capitalisation is forecast to reach around US$2trn (£1.4trn) by 2030 according to McKinsey (2024).
And all this is against a backdrop of political and regulatory uncertainty, leaving managers craving jurisdictional stability and making predictable regulation a competitive differentiator. Ultimately, managers and investors want solutions that work, that offer regulatory credibility and that can guarantee day-to-day operational efficiency.
Foundation
As the private markets evolve towards flexible, evergreen and hybrid models, Jersey’s dedicated workforce of almost 14,000 professionals is working with managers and their tax advisers to help navigate this shifting landscape – providing certainty around structuring and the expertise required to support the next generation of private capital vehicles.
Critical to this is Jersey’s foundation of legal certainty and political and economic stability, offering a platform for managers and investors that is straightforward, reliable and familiar, with no surprises.
This is accompanied by Jersey’s tax neutrality and simple tax regime, with no tax on capital gains, wealth or asset management. It means that capital from around the world can be pooled in Jersey, in a single place, so that it is only taxed once. There are very few places in the European time-zone that can offer such tax neutrality.
In a world of increasing geopolitical and regulatory complexity, Jersey offers a clear, stable and predictable platform for global private capital.
Future trends
Just as evolution in the cross-border investment space is supported by jurisdictional stability, however, those shifts are also placing a premium on jurisdictional agility and innovation.
The expansion of the private markets into the wealth channel requires trusted jurisdictions capable of balancing innovation with investor protection – a space where Jersey’s regulatory framework excels.
Jersey has, for example, continued to enhance its structuring environment – in particular, updating its sector-leading Jersey Private Fund regime last year to make it more accessible and flexible to private investors, offering approval in as little as 24 hours.
Further amendments are also in the pipeline this year to streamline Jersey’s regulatory framework, so that bringing new investment products to market is both quicker and more cost-effective.
Jersey is also on the front foot in developing a cutting-edge regulatory regime to support digital assets and stablecoin growth. The Jersey Financial Services Commission was one of the first regulators globally to publish guidance around virtual assets almost a decade ago and in 2024 it published updated guidance on the tokenisation of real-world assets.
And, as liquidity solutions become central to private capital strategies, Jersey’s expertise in structured finance, SPVs and co-investment vehicles positions it as a natural platform for fund innovation.
The cross-border investment funds space is changing rapidly; the future is flexible, global and technology-enabled. Jersey is well positioned to support that evolution, underpinned by a dynamic and continually evolving funds regime, and works closely with tax advisers to help managers and investors realise their ambitions.
By Elliot Refson, Head of Funds at Jersey Finance










