Good to know!
Milo / 04.01.2021
- The NAIF is a structure regulated under the AIFMD, just it does not have a license. Its 'regulated' status comes from the fact that it is managed by a licensed AIFM. Therefore, I would replace 'Unreg.' with 'Unlicensed' but put an asterisk or something that explains that it is regulated under the AIFM as it relies on the AIFM license of its manco;
- The NAIF is not 'tax transparent', it is a an entity with a fiscal 'persona' on its own;
- In Malta there is not concept of ' Well Informed Investors', there is a category called 'Qualified Investors' (so lower thresholds) but it only applies if the investor is Maltese resident, it does not really apply when marketing abroad (only Professional Investors as defined by MiFID are a target);
- Only Maltese ISINs can be provided for the share classes as we apply for them with the Malta Stock Exchange;
- Indeed, a Maltese NAIF's strength is that such a structure is decidedly cheaper than a Lux RAIF the lower the AUMs. That is why it is preferable to launch a Maltese NAIF for low seeding AUMs than a RAIF (also considering Lux service providers may refuse outrights to do a RAIF for 5mm EUR, whereas the Maltese ones will not), whereas the economical advantage of the NAIF over the RAIF decreases higher the AUMs are. Given the better recognition of Luxembourg, it definitely does not make sense to promote at all a Maltese fund solution for AUMs higher than, say, 50mm EUR.