SPVs in Isle of Man, Luxembourg, and Mauritius Explained

#Fund Administration & SPV Services

Special Purpose Vehicles (SPVs) have become an essential part of modern investment and corporate structuring. Whether used for holding assets, isolating risk, or facilitating complex financial transactions, SPVs provide flexibility, confidentiality, and efficiency  when set up in the right jurisdiction.

Among the top global locations for SPVs are the Isle of Man, Luxembourg, and Mauritius  each offering distinct advantages, regulatory frameworks, and tax benefits. Understanding how these jurisdictions differ helps investors and fund managers choose the most suitable structure for their objectives.

1. What Is an SPV?

An SPV (Special Purpose Vehicle) is a separate legal entity created for a specific and limited business purpose  often to hold assets, issue securities, or manage investment risks.

SPVs are commonly used for:

  • Securitisation and structured finance

  • Holding real estate or intellectual property

  • Isolating high-risk investments from parent companies

  • Private equity or venture capital vehicles

  • Fund and investment note issuance

By ring-fencing assets and liabilities, SPVs enhance transparency and protect the main operating company from financial exposure.

2. The Isle of Man SPV

The Isle of Man is a long-established financial centre known for its stability, legal predictability, and pragmatic regulation.

Key features:

  • Legal forms: Typically private companies limited by shares, with straightforward incorporation.

  • Regulatory oversight: Governed by the Isle of Man Financial Services Authority (IOMFSA).

  • Tax regime: 0% corporate income tax for most entities; no capital gains or withholding tax.

  • Confidentiality: Beneficial ownership disclosure is regulated but kept under strict confidentiality.

  • Common uses: Aircraft and ship leasing, structured finance, and international asset-holding vehicles.

Why investors choose it:
The Isle of Man offers simplicity, a strong legal system rooted in English law, and easy access to UK and EU financial markets  ideal for institutional-grade SPV setups.

3. The Luxembourg SPV

Luxembourg remains Europe’s gold standard for fund and structured-finance SPVs. It combines a sophisticated financial ecosystem with deep investor trust.

Key features:

  • Legal forms: The most common are Société de Titrisation (Securitisation Companies) or Securitisation Funds (Fonds de Titrisation).

  • Regulation: Securitisation vehicles fall under the 2022 Luxembourg Securitisation Law.

  • Tax benefits: Flexible tax neutrality  income passes through to investors without double taxation.

  • Double-tax treaties: Over 80 treaties make Luxembourg an excellent jurisdiction for cross-border transactions.

  • Common uses: Bond issuance, real estate investment vehicles, and private equity structures.

Why investors choose it:
Luxembourg offers unmatched credibility within the EU, making it the preferred choice for institutional investors and asset managers seeking compliant, scalable structures.

4. The Mauritius SPV

Mauritius serves as a bridge between Africa, Asia, and global capital markets. Its appeal lies in its modern regulatory framework, strategic tax treaties, and cost-efficient setup.

Key features:

  • Legal forms: Global Business Companies (GBCs) or Authorised Companies.

  • Regulation: Licensed and supervised by the Mauritius Financial Services Commission (FSC).

  • Tax incentives: Effective corporate tax as low as 3% for GBCs, with access to 40+ double-taxation treaties.

  • Substance requirements: Resident directors, local accounting, and bank accounts for full treaty access.

  • Common uses: Fund structuring, investment holding, and regional SPVs for India, Africa, and the Middle East.

Why investors choose it:
Mauritius offers a balance of tax efficiency, credibility under OECD standards, and proximity to emerging markets making it ideal for both institutional and private investors.

5. Choosing the Right Jurisdiction

The best SPV location depends on your investment goals, investor base, and tax exposure.

  • Choose Isle of Man if you need simplicity, confidentiality, and cost-effective asset holding.

  • Opt for Luxembourg when dealing with institutional investors, EU compliance, or large-scale securitisation.

  • Select Mauritius for treaty access, cost efficiency, and      gateway positioning between Africa and Asia.

A well-structured SPV not only enhances legal protection but also improves investor confidence and regulatory clarity.


6. Final Thoughts

SPVs are powerful tools when established correctly. The choice of jurisdiction shapes how efficiently they operate from tax treatment and reporting to investor credibility.

Partnering with an experienced corporate services provider ensures seamless setup, compliance, and ongoing administration. At Devenir Corporate Services, we assist clients in establishing SPVs across key global jurisdictions, aligning structure with strategy and regulation.


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