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Fund of Funds: A Tax Haven for Foreign Investors?
18 Mar
Summary
- Funds of Funds attract foreign investors seeking better tax structures.
- FoFs can invest in popular foreign AIFs, enhancing global appeal.
- Taxation of FoFs depends on the underlying AIF's category.

Funds of Funds (FoFs) are proving instrumental in attracting foreign capital, primarily by offering enhanced tax advantages that appeal to international investors.
These investment vehicles provide a similar tax framework to mutual funds, making them an attractive option for those looking to optimize their tax liabilities.
Furthermore, FoFs leverage their ability to invest in Alternative Investment Funds (AIFs) that have established popularity abroad. This strategy not only broadens investment opportunities but also enhances the overall appeal and brand recognition of the FoF compared to a standalone domestic AIF.
The tax implications for FoFs are intrinsically linked to the structure of the underlying AIFs. Typically, Category I and Category II AIFs, including FoFs structured within these categories, benefit from pass-through taxation. Under this model, income is taxed directly in the hands of the investors, rather than at the fund level, leading to greater tax efficiency.
Conversely, Category III AIFs do not offer pass-through status. Instead, they are subject to taxation at the fund level. This distinction renders them less tax-efficient, as their tax rates are often nearly double those applicable to Category I and Category II AIFs.




