As international fund structuring becomes more complex, advisers and fund professionals continue to re-evaluate their options. The UK’s Qualifying Asset Holding Company (QAHC) regime and Jersey’s well-established SPV structures offer powerful solutions for tax-efficient, substance-compliant, and operationally sound investment holding vehicles.

At Oakbridge, we specialise in administering both UK and Jersey holding structures – supporting tax advisers, lawyers and investment managers seeking clarity, compliance and efficiency across jurisdictions.

What is a UK QAHC? A Fund Structuring Tool

Introduced in 2022, the UK QAHC regime is designed to make the UK more competitive as a fund holding jurisdiction. QAHCs are UK tax-resident companies offering broad tax exemptions and are primarily aimed at institutional investors and investment funds.

Key UK QAHC benefits:

• Capital gains exemption on disposal of qualifying shares and overseas property
• Exemption from corporation tax on overseas property income (if taxed abroad)
• No UK withholding tax on interest paid
• Capital return flexibility for investors
• Enhanced remittance basis may apply for non-UK domiciled fund managers
• No stamp tax on share or loan repurchases

To qualify, QAHCs must:

• Be UK tax resident, but do not need to be UK incorporated
• Their equity securities must be unlisted
• Not be a UK Real Estate Investment Trust (REIT)
• Be at least 70% owned by “Category A” investors (e.g. pension funds, qualifying funds)
• Be structured around an investment business, not trading
• Avoid exposure to listed equities (unless in “take private” scenarios)

Why Jersey SPVs Still Lead for Cross-Border Fund Structuring

Jersey has long been the jurisdiction of choice for private capital structures due to its tax neutrality, stability and international reputation.

Advantages of Jersey domiciled SPVs:

• Tax-neutral jurisdiction
• Flexible capital structures
• No withholding tax on distributions
• Well-established regime for private equity and real estate
• Strong legal framework and political stability
• Widely recognised by institutional investors, lawyers and regulators

When are QAHCs used in UK Fund Structures

A QAHC is often the right choice if:

• Investors are institutional, for example pension funds and qualifying investment funds
• The structure involves private credit, overseas real estate, or other private market strategies
• Managers want to avoid substance burdens in other jurisdictions

Using Jersey and UK Structures Together

For many institutional fund managers, the best approach is not either/or—but both.

By combining Jersey SPVs with UK QAHCs, it is possible to:

• Optimise tax outcomes for different investor types
• Satisfy regulatory, operational and substance needs in parallel
• Create flexible, multi-layered structures
• Jersey incorporated companies can offer greater flexibility in paying out capital and making distributions.

Oakbridge provides seamless, single-provider administration across both jurisdictions.

How Oakbridge Supports Fund and Corporate Structuring

Oakbridge delivers specialist fund administration and corporate services for clients using UK and Jersey entities. We support advisers and clients across:

• QAHC setup and ongoing compliance
• Jersey and UK SPV formation, directorships, and governance
• Accounting, tax, and regulatory support
• Structuring input with a practical, commercial focus

We work directly with UK law firms, tax advisory practices, and fund managers – ensuring joined-up execution from structuring through to ongoing operations.

FAQs: UK QAHCs, Jersey SPVs and Fund Structuring

What is a UK QAHC?

A QAHC is a UK tax-resident holding company offering exemptions on capital gains and overseas income, tailored for institutional investors and fund managers.

Who can invest in a QAHC?

QAHCs must be majority-owned by “Category A” investors—such as pension funds, qualifying funds, charities and insurance companies.

Can I use both a UK QAHC and a Jersey SPV in a fund structure?

Yes. Many funds combine both jurisdictions to optimise tax and operational flexibility.

Is it possible for a Jersey registered company to be a UK QAHC?

Yes, subject to management and control of the entity being in the UK.

Is a Jersey SPV tax-efficient for UK investors?

Yes. Jersey can offer tax neutrality, and Oakbridge can assist with tax compliance and efficiency.

What makes Oakbridge different?

What sets Oakbridge apart is our independent ownership and director led service, which allows us to deliver fund structuring solutions with a level of responsiveness, stability, and a long-term commitment.

Talk to Our Experts

If you’re a tax adviser, lawyer or investment manager exploring fund structuring options, we’re here to help. Whether you’re launching a new fund, restructuring an existing platform or assessing eligibility, Oakbridge offers the experience, clarity and cross-jurisdictional support you need.

Get in touch with our UK or Jersey team today.