Cayman Funds: Structures, CIMA Regulation and Taxation 2026

To structure a fund in Cayman, choose the vehicle (exempted company, SPC, unit trust or limited partnership), place it in a CIMA category and hire an administrator and an auditor. For Brazilians, Law No. 14,754/2023 (Lei 14.754/2023) sets the tax: 15% on earnings or, if they control a passive fund, on profit calculated on December 31.

Which Vehicle Should You Use for a Fund in Cayman?

CIMA (Cayman Islands Monetary Authority), the local regulator, lists four commonly used fund vehicles. The choice depends on how the fund raises capital, distributes results and separates assets.

• •Exempted company: can redeem or repurchase its own shares, so it suits open-ended funds. It also works as a closed-ended fund.
• •Segregated portfolio company (SPC): an exempted company with segregated portfolios. It allows different groups to protect their assets within a single entity.
• •Unit trust: the fund is constituted under a trust. In the licensed category, the law requires as trustee a trust company licensed in Cayman.
• •Exempted limited partnership: the distribution of results and each partner's role come from the partnership agreement. Ask the local lawyer for the draft before deciding.

There is also a division by type of fund. CIMA describes a mutual fund as one that issues interests redeemable or repurchasable at the investor's option. Funds that pool investors' money without day-to-day control, managed by the operator for a fee, fall under the 2020 private funds law, with their own registration and fee.

Which Fund Categories Does CIMA Regulate?

The Mutual Funds Act (2025 Revision) separates funds by category. The classification defines who supervises the fund and what it must submit.

CI$ is the Cayman Islands dollar. CIMA itself converts the registered fund minimum to US$ 100,000.

How Long Does It Take to Register or License a Fund?

CIMA reports about five business days to register a mutual fund and four to six weeks to license it. Both periods count from receipt of all the documentation.

The registration or license application includes, according to CIMA:

1. •Form on the REEFS portal, according to the category.
2. •Notarized declaration (affidavit) for electronic filings.
3. •Certified copy of the certificate of incorporation or registration.
4. •Administrator's letter of consent.
5. •Auditor's letter of consent.
6. •Offering document.
7. •Registration or license fees and the administrative filing fee.
8. •MLRO form (the anti-money laundering reporting officer).

Operators of licensed funds also submit a personal questionnaire, identity document, résumé, references and a criminal record certificate.

What Official Fees Does CIMA Charge a Fund?

CIMA's fee schedule, updated on January 1, 2026, gives the amounts in CI$ and the conversion to US$ at 0.82.

The annual fee is due on January 15. If late, the law and the schedule provide for an additional one twelfth of the fee for each month outstanding. In 2026 CIMA raised the annual fee for a registered fund from CI$ 3,675 to CI$ 4,125 and for the master fund from CI$ 2,625 to CI$ 3,075. The fund also pays the Annual Return (FAR) fee. CIMA says fiscal years ended through December 31, 2025 follow the old amounts, so check the current amount in the schedule.

How Much Do the Lawyer, Administrator and Auditor Cost?

These fees have no official table. They depend on the size of the fund, the strategy and the chosen provider. That is why this guide gives no estimates. Ask each provider for a written quote and compare what is included: incorporation, CIMA filing, annual maintenance and reporting.

Does a Regulated Fund in Cayman Need an Audit?

Yes. Section 8 of the Mutual Funds Act requires the regulated fund to have its accounts audited every year, by an auditor approved by CIMA. The accounts follow IFRS or the accounting principles of jurisdictions the law accepts, such as the US, Japan and Switzerland. The fund sends the audited accounts to CIMA within six months after the end of the fiscal year, unless an extension is granted. The legal definition of a regulated fund covers sections 4(1), 4(3) and 4(4)(a).

How Is a Brazilian Taxed on a Cayman Fund?

The fund may have its own local regime, but that does not displace Brazilian law. Law 14,754/2023 requires an individual resident to report, in the Annual Adjustment Return (DAA), the earnings on capital invested abroad, separately from other income. The rate is 15% on the annual portion, with no deductions (art. 2). What changes is when the tax applies, and that depends on control.

Three points of the law weigh on the modeling:

• •Control: the law treats as controlled the entity, including an investment fund, in which the individual has the upper hand in decisions or the power to elect most of the managers, or more than 50% of the capital or of the rights to profits and assets (art. 5, § 1).
• •Segregated classes: in funds with classes of units with segregated assets, each class is a separate entity for measuring control (art. 5, § 2). This matters in an SPC.
• •Passive fund: the art. 5 rule only applies to a controlled entity in a favored-taxation country or regime, or with own active income below 60% of total income (art. 5, § 5). The law excludes financial investments and interest from own active income (art. 5, § 6), so a fund that only invests tends to be passive.

Other useful rules: tax paid abroad can be deducted if a treaty or reciprocity exists, within the limit of Brazilian tax (art. 4); realized losses on financial investments abroad offset earnings of the same type (art. 9); and the exchange-rate variation on principal invested in a controlled entity becomes a capital gain on sale (art. 7).

What Changes If I Opt for the Art. 8 Transparency?

Art. 8 lets you report the controlled entity's assets, rights and obligations as if they were yours, instead of following arts. 5, 6 and 7. The option applies per entity, is irrevocable and irreversible as long as you hold the entity and, if there is more than one partner, must be exercised by all individual partners resident in Brazil. For an interest acquired from 2024 on, the option is made in the first DAA after the acquisition. The full comparison is in the guide on opaque or transparent offshore.

Do I Need to Report the Fund to the Central Bank?

It depends on total assets abroad. According to the CBE Manual (Declaration of Brazilian Capital Abroad), anyone with US$ 1,000,000 or more in assets and rights abroad on December 31 files the annual declaration. The deadline runs from February 15 to April 5 of the following year. Late filing or incorrect information can bring a fine of up to BRL 250,000. The CBE is a foreign exchange obligation and does not replace the Receita's DAA.