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E-book Czech Investment Funds, Sub-funds, SICAV

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E-book: Czech Investment Funds, Sub-Funds & SICAV

Professional Investment Structures, Regulation and Fund Architecture



This professional e-book explains in a clear and practical way how investment funds, sub-funds and SICAV structures work in the Czech Republic — and how they compare, in hard numbers, with the fund regimes of Luxembourg, Ireland, Germany, the Netherlands, France, Italy and Switzerland.

You will learn when it makes sense to establish a standalone investment fund, when it is more efficient to launch a sub-fund within an existing SICAV platform, what regulatory requirements apply, what a fund genuinely costs to set up and to run, how the 5% tax rate is actually earned — and at what level of assets a fund stops being an expense and starts being an advantage.

The e-book is designed for entrepreneurs, investors, family offices, real estate projects, private equity and credit structures, capital managers, and the lawyers, tax advisers and accountants who advise them.

This material is for information only and does not replace individual legal, tax or accounting advice.


What you will find inside the e-book "Czech Investment Funds, Sub-Funds & SICAV"

  1. Prologue

  2. Introduction: When a Fund Makes Sense — and When It Does Not

  3. The Legal Framework and Supervision

  4. Forms of Fund in the Czech Republic

  5. The SICAV: A Fund with Variable Share Capital

  6. Sub-Funds and Ring-Fencing

  7. Fund versus Sub-Fund: A Decision Framework

  8. The Qualified Investor Fund

  9. Section 15 ZISIF: What It Is and What It Is Not

  10. Manager, Administrator and Depositary

  11. The Platform Model: Why the Czech Republic Is Cheap

  12. Setting Up a Fund, Step by Step

  13. Fund Rules, Strategy and Valuation

  14. Accounting, Audit and Reporting

  15. Tax I: The 5% Rate and the Section 17b Test

  16. Tax II: Taxing the Investor

  17. The Costs of a Fund and of a Sub-Fund

  18. The Economics: At What Size a Fund Pays for Itself

  19. Comparison I: Luxembourg and Ireland

  20. Comparison II: Germany, the Netherlands, France, Italy, Switzerland

  21. Ten Reasons the Czech Republic Wins — and Four Why It Does Not

  22. Case Studies

  23. The Most Common Mistakes, a Checklist, and a Conclusion


Why the Czech Republic — the short version

The entry threshold. A Czech qualified investor fund becomes economically viable at roughly EUR 4.1 million of assets. A Luxembourg RAIF, on practitioners' own figures, at EUR 20–30 million. That is a five- to sevenfold difference — and it is the single reason most Czech families and entrepreneurs can have a regulated fund at all.

The platform model. The founder does not need an AIFM licence, EUR 125,000 of initial capital, or a compliance team. An existing licensed Czech management company provides all of it.

The regulator's fee. Registering a sub-fund with the Czech National Bank costs CZK 2,000 — about EUR 82.

Real estate. An Irish fund with 25% or more of its assets in Irish property suffers 20% IREF withholding tax on distributions and on redemptions. A German fund pays 15% on German property income. From 1 January 2025, a Dutch FBI may no longer hold property directly at all — do so and it pays 25.8%. A Czech fund holding property through SPVs keeps its 5%.

No tax on assets. Luxembourg levies its taxe d'abonnement on net asset value whether the fund earned anything or not. The Czech Republic taxes profit, not size.

The exit. A Czech individual who holds investment shares for more than three years is exempt on sale — and since 2026, with no ceiling at all.


What we also tell you — honestly

The Czech Republic does not have the lowest fund-level tax rate in Europe. Ireland and Malta are at zero; Luxembourg charges 0.01% of NAV. If rates were all that mattered, the Czech Republic would lose.

The book therefore also sets out the four places where it loses: prestige with institutional investors, a very narrow pool of depositaries, slower time to market than a Luxembourg RAIF, and the limits of cross-border distribution and the koruna. A structure sold as flawless is a structure sold dishonestly.


What you receive

You receive a practical framework for deciding whether a standalone fund, a sub-fund in an existing SICAV, or a simpler holding structure suits your project — and the three thresholds (legal, tax break-even, and economic) that determine the answer.

The e-book explains the difference between a fund and a sub-fund; the roles of the manager, administrator, depositary, auditor and independent valuer; regulatory requirements and realistic timelines; setup and operating costs taken from published price lists rather than estimates; how the 5% rate depends on the fund's balance sheet and not on its name; and why the same profit can be taxed at 19.25% or at 5% depending on how the investor exits.

Six case studies show how this works in practice — including a real estate portfolio that would have failed the Section 17b test, a family office that was too small for Luxembourg, and a fund that chose Prague over Dublin once it understood IREF.

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