ARTICLE
10 September 2025

Private Capital - Typical Fund Structures

AC
Arthur Cox

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Arthur Cox is one of Ireland’s leading law firms. For almost 100 years, we have been at the forefront of developments in the legal profession in Ireland. Our practice encompasses all aspects of corporate and business law. The firm has offices in Dublin, Belfast, London, New York and Silicon Valley.
We are the leading Irish law firm advising participants in the private capital industry, including investment managers, private funds, investment banks and end-investors.
Ireland Corporate/Commercial Law
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We provide a full-service, coordinated offering to our clients with dedicated and collaborative specialists in our funds, global regulatory, finance, tax, corporate and real estate teams.

We support private capital investors and their portfolio companies at all stages of the private capital lifecycle from fund and vehicle formation to fundraising investment and exit across a wide range of alternative products and funds, including hedge, private asset, private equity, private credit, loan portfolios, life settlements, infrastructure (including renewable infrastructure) and real estate.

Our Corporate and M&A Group is the leading Irish legal adviser to private equity clients on the acquisition and disposal of Irish businesses and have acted on most of the significant Irish transactions.

Our Real Estate Group advise most of the leading real estate private equity investors on the acquisition, asset management and disposal of Irish real estate assets.

Our Finance and Structured Finance Group act for many of the leading private equity firms in their acquisition and real-estate finance transactions and we act for many of the leading private debt lenders in Ireland and across Europe.

Our Asset Management and Investment Funds team advise on the establishment and regulation of a wide range of Irish investment funds.

Our Tax Group advise on the structuring of all types of private capital investment through Ireland.

Irish Structures

Globally recognised as a highly favourable destination for the establishment of private funds and asset structures, Ireland offers a compelling array of advantages. These include its transparent and flexible regulatory environment, on-shore location, access to the European Union management and marketing passports, its status as a common law jurisdiction, the tax efficiency of the investment vehicles available and the well-established and efficient service provider industry.

For these reasons Ireland offers an extensive array of structures facilitating investment in the full range of assets, as set out below. We advise on the establishment of all of these structures for many of the leading Private Capital industry participants.

Structures established in Ireland include:

  • Regulated and unregulated direct lending vehicles lending to borrowers in the U.S., Europe and elsewhere
  • Vehicles for the acquisition of loan portfolios, performing and non-performing
  • Structures for private equity and other corporate transactions
  • Vehicles for the acquisition of real estate in Ireland and Europe
  • Originator structures, originating assets for CLO transactions

Investment Strategies Through Irish Vehicles

Credit / Loan Origination Can be structured through a QIAIF or can also work via a S.110 Company
Real Estate Typically structured through QIAIF structures if a direct real estate holding; real estate loan portfolios usually structured through S.110 Companies
Loan Portfolio Acquisitions Usually structured through a S.110 Company
Music / Film Royalties Typically structured through a QIAIF (treated as Irish resident under Irish / US Treaty) but can also work via a S.110 Company
Private Equity Typically structured through a QIAIF not a S.110 Company, but with careful structuring can also use a S.110 Company
Intra Group Funding Transactions typically structured through a QIAIF (treated as Irish resident under Irish / US Treaty) but can also work via a S.110 Company

This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

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