Cayman Islands Segregated Portfolio Company

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Protected Cell and Segregated Portfolio Companies

Cayman Islands Segregated Portfolio Company Formation

The Cayman Islands introduced the Segregated Portfolio Company (SPC) through amendments to the Companies Law in 1998. The Cayman SPC is one of the world's most frequently used protected cell structures, widely deployed for hedge funds, mutual funds, captive insurance, and structured finance transactions. Each segregated portfolio within an SPC has its own assets and liabilities that are legally isolated from other portfolios and from the general assets of the SPC.

Statutory Segregation

The Companies Law (as amended) provides that the assets of a segregated portfolio can only be used to meet the liabilities attributable to that portfolio. Creditors of one portfolio have no recourse to the assets of another portfolio or the general assets of the SPC.

Investment Fund Use

The Cayman SPC is the preferred structure for multi-strategy hedge funds, fund of funds, and managed account platforms, allowing multiple investment strategies to operate under a single Cayman Islands Monetary Authority (CIMA) regulated structure.

No Direct Taxation

Cayman Islands SPCs are exempt from all direct taxes including corporation tax, capital gains tax, withholding tax, and stamp duty. CIMA provides a tax exemption certificate for 20 years (renewable) to qualifying companies.

CIMA Regulation

SPCs used as investment funds are regulated by CIMA under the Mutual Funds Act. Insurance SPCs are regulated under the Insurance Act. CIMA is a respected regulator with comprehensive supervisory powers and international cooperation agreements.

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