Reflections on the Irish Funds US Seminar and Ireland’s Strengths as a Private Funds Domicile
As St. Patrick’s Day approached, I had the pleasure of attending the annual Irish Funds US Seminars, in Greenwich, Connecticut, before moving to New York. These events brought together financial leaders and innovators from all over the North American and Irish investment funds space, and I was honoured to be asked to participate in the final panel of the New York event. Accompanying me on this trip were my colleagues David Carroll, Partner, Head of Capital Markets, and Charys Magpayo, Senior Manager, Audit, enhancing our collective experience with their insights, expertise and company.
Nicholas Blake-Knox, Chairperson of Irish Funds, inaugurated the events by highlighting the deep-rooted historical ties between Ireland and Greenwich. He went on to emphasise the significant contribution to Ireland’s funds and asset management industry from US fund managers, who account for a full 33% of assets in Ireland’s Assets under Management (AuM). He pointed out key advancements, such as collaborations with the Central Bank of Ireland regarding strategies for private assets and improvements in Ireland’s capabilities within the private markets.
Amid an atmosphere imbued with characteristic optimism and can-do spirit, the seminars provided a dynamic platform for asset management leaders to engage in rich dialogue and share actionable insights. These gatherings helped both seasoned experts and new players alike forge paths for future development. Both legs of the event were well attended, showcasing Ireland and its role in the international fund management arena.
At the seminar’s closing act in New York, I moderated “The Private Funds Toolkit – Launching from Ireland” before 200 industry leaders, joined by Lloyd Collier from JTC Group, Melíosa O’Caoimh of Northern Trust and Scott Parkin of Zeidler Group. Our discussion drew out Ireland’s advantages for private funds: regulatory agility, tax efficiency, global distribution and operational excellence.
IRELAND’S REGULATORY ADVANTAGES: WHERE FLEXIBILITY MEETS FAMILIARITY
My first panel question was to Scott Parkin from Zeidler Group, a specialist funds law firm, about the regulatory advantages of Ireland and the various legal structures available, specifically the Irish Collective Asset-management Vehicle (ICAV) and the Investment Limited Partnership (ILP), and how they fit into the private markets toolkit.
What emerged from the panel, and from some of the prior talks in the Seminar, included:
Regulatory toolkits provide agility: Frameworks like the ICAV and ILP, highlighted by our panel’s experts, offer segmented liability and LP-friendly governance, critical for private equity and credit strategies. This matters because it allows Alternatives Managers to launch operations more quickly and cost-effectively than in other jurisdictions. How much quicker and how much cheaper? It was said at the event that launching in Ireland is up to 40% cheaper on average compared to other European jurisdictions and could be up to 50% faster too.
Common Law Advantage: The foundational strength of common law in Ireland aligns well with US and international business practices, making it a straightforward choice for global investors. The importance of this becomes clear to anyone restructuring a fund mid-stream – they soon appreciate Ireland’s common-law agility! The recent EU pre-marketing reforms, allowing managers to gauge interest before full launches, further tilt the scales, a point appreciated by multiple speakers through the Seminar.
Tax Efficiency as a factor: Ireland’s 0% withholding tax for private credit (via US treaties) emerged as an important benefit, earlier highlighted at the Greenwich Seminar. Ireland’s tax treaty with the US provides a unique gateway for non-US investors in Irish domiciled credit funds. In short, it was noted that Ireland’s tax environment includes no corporate, capital gains, or withholding tax for non-Irish investors, and coupled with an extensive double tax treaty network, it offers an ideal setting for establishing tax-efficient fund structures.
A DIPLOMATIC DANCE
A lively debate ensued when I asked both Lloyd Collier (JTC Group) and Scott Parkin (Zeidler Group) to discuss why they believe Ireland is a preferable domicile compared to other EU jurisdictions. This was tongue-in-cheek, intended to stir some hearty debate from the panel, which it did.
Cost efficiency (40% savings), tax efficiency (no withholding tax), time-zone advantage (5 hours, not 6 hours difference with New York), direct flights to Ireland, and the delegated management model were all cited.
I invited Lloyd to expand and demystify the delegated management model, a cornerstone of Ireland’s appeal for cross-border funds. It was elaborated that this framework, while anchoring funds in Ireland’s robust regulatory regime, allows for a globally dispersed operational ecosystem. This model is particularly relevant as it illustrates how, although funds may be domiciled in Ireland, the operational ecosystem can span multiple jurisdictions, with General Partners (GPs) in one country (for example the United States), Limited Partners (LPs) in another (for example, spread across Europe or Asia) and underlying assets in a third jurisdiction, all managed under an Irish structure that supports this complex arrangement. Such an approach delivers three advantages: jurisdictional flexibility, operation simplicity and investor confidence.
Finally, with my tongue firmly in my cheek once again, I challenged Melíosa to comment on the fact that €2 trillion of the assets under administration in Ireland are actually domiciled in other jurisdictions. Although she remained neutral, noting Northern Trust’s operation across multiple jurisdictions, she did acknowledge the competitive positioning and strength of the ecosystem of Ireland in the global funds industry.
OPERATIONAL AND DISTRIBUTION CAPABILITIES
While Ireland’s regulatory and tax advantages set the stage, discussions at my panel and throughout the US Seminar revealed what truly powers fund success – Ireland’s distribution capabilities. Here’s how Ireland’s delivers:
UCITS (Undertakings for Collective Investment in Transferable Securities): The UCITS brand is recognised not only as a kitemark of quality within the EU but also as a premier vehicle for distributing investments to Asia and Latin America. Its reputation for quality ensures that it is the preferred choice for investors looking to access markets in these regions. The UCITS brand extends far beyond European borders, facilitating global investment flows and showcasing the EU’s influence in international finance.
On the note of global distribution, another panellist, Dirk Grosshans from Universal Investment, said Ireland serves as an ideal hub for global fund distribution, capable of reaching markets in up to 90 countries.
Private Assets AuM Growth: In 2025, Investments in private assets are expected to reach €15 trillion in AUM, up from €10 trillion in 2010. Consensus estimates suggest that by the end of 2027, private capital AUM could reach €18 trillion, a good chunk of which is expected to be domiciled in Ireland.
Pre-marketing Capability: Ireland’s regulatory framework now permits pre-marketing activities, empowering fund managers to assess investor interest and refine their offerings prior to a full-scale launch. This capability is pivotal for strategically positioning new funds in a competitive marketplace, enabling optimal alignment with market and investor expectations. Not long ago, managers weren’t able to really test their hypothesis before launch. That pre-marketing ability has reduced the failure rate for American managers coming into the EU dramatically.
HIGHLIGHTS FROM SPEAKERS AROUND THE EVENT
Beyond my panel discussion, and in conversations with colleagues David Carroll and Charys Magpayo during the seminar, several additional strategic advantages for Ireland emerged:
Innovation and technological advancements as a differentiator: Ireland is a leader in financial technology, utilising proprietary software and platforms that enhance fund management efficiency and investor engagement, supporting activities from Exchange Traded Fund (‘ETF’) wrappers for mutual funds to comprehensive digital asset management solutions.
EU and Irish Jurisdictional Innovations: Jennifer Carroll MacNeill TD, Irish Minister for Health (formerly Minister for Financial Services), speaking in New York, highlighted Ireland’s significant contributions to the U.S. financial services sector and its commitment to innovation, citing private asset funds and sustainable finance as examples.
David highlighted to me an important contextual point also. The EU is actively working to reduce regulatory complexity by 25% by 2029, aiming to streamline operations and enhance market efficiency and accessibility. Additionally, the EU’s new Savings and Investment Union plans to mobilise roughly €9 trillion in retail bank accounts across Europe to stimulate investment and savings, enhancing opportunities to gather assets from a relatively untouched source.
In Ireland, innovation continues with flexible financial products like EFT wrappers for mutual funds, which improve liquidity and tax efficiency. The financial landscape also accommodates a range of operational models from completely independent setups to collaborative approaches with third-party management company umbrellas, ensuring effective fund management across the spectrum.
CONCLUSION
These insightful discussions with my fellow panellists and colleagues showcased to our audience Ireland’s unique advantages as a domicile for private funds, including its robust regulatory environment, strategic geographic positioning and the sophisticated ecosystem it uses to support US fund managers looking to raise assets from the EU – and around the world.
Many thanks to Irish Funds for the opportunity to moderate, to the organisers, and all who made this such a valuable event, David, Charys and I are already looking forward to next year’s Seminar.
Contact Us
If you would like to gain deeper insights into this area and explore how it may impact your business, we invite you to connect with Paul Traynor, Partner and Head of Governance, Risk, and Compliance or Ian Wilson, Partner and Head of Funds.
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Why Ireland is the Top Choice for U.S Asset Managers?
The European market is fast becoming an established focal point for U.S. asset managers looking to diversify their investor base, launch new funds, and enhance their global footprint. With regulatory reforms, market access, and a welcoming business environment for the U.S. funds industry, Ireland has emerged as a leading destination for U.S. managers seeking to domicile funds and raise capital from European investors.
Why Europe now?
European investors have been drawn to U.S. managers for some time for their scale, competitiveness, and resilience. This includes leading U.K. and European investors, such as BAE System and Shell’s pension funds, each with over $25 billion in assets. The Financial Times reported that “…Americans are profiting as European investors shift money into low-cost tracking funds[,] exchange-traded funds and unlisted alternatives, including private equity, private credit, and infrastructure.”
Impact of Brexit and Ireland’s Rise
Brexit has fundamentally reshaped the European fund landscape. With the U.K. no longer part of the E.U., its ability to serve as a gateway to access E.U. investors has been severed. This has forced firms to look elsewhere to maintain access to the E.U.’s €20 trillion institutional investor market.
Ireland has stepped into this void, offering seamless access to E.U. investors through its E.U. passporting rights. It has a robust infrastructure, a skilled workforce, and allocator-friendly policies that investors value. As a native English-speaking jurisdiction with a regulatory environment familiar to U.S. managers, Ireland provides the ideal bridge between the U.S. and Europe. Ireland is the natural choice for U.S. managers looking to capitalize on European opportunities.
Ireland: The Preferred Fund Domicile
Ireland emerged as the preferred fund domicile when U.S. managers sought to launch into Europe. Since the Irish Limited Partnership (ILP) reform in 2021, registrations from U.S. managers have grown significantly, with the structure now a leading choice for private equity, real estate, and credit funds. For example, according to Irish Central Bank data, Blackstone and Lazard Asset Management launched new funds in Ireland under the ILP structure in mid-to-late 2024. According to the Irish Funds Association, annual asset growth for Ireland-domiciled alternative funds grew 22% to November 2024.
Ireland’s Value Add for U.S. Managers
Whilst Luxembourg and Ireland have hotly competed in recent years, Ireland has pulled ahead, becoming a top choice for U.S. asset managers seeking European expansion. Recent figures published by the European Fund and Asset Management Association (EFAMA) show that Ireland saw the “vast majority” ($179 billion) of cross-border fund sales in 2023, outstripping Luxembourg across both traditional and alternative strategies. The same report also shows that Ireland and Luxembourg remain dominant in the private market funds space, with Ireland holding 19% of alternative funds versus Luxembourg’s 16%.
This is because Ireland offers distinct advantages over other jurisdictions. It is the only native English-speaking E.U. member country that offers full market access to European investors whilst benefiting from a common law system and a U.S.-aligned regulatory framework. This simplifies compliance and feels familiar to U.S. managers.
Ireland is a cost-efficient jurisdiction with competitive fees and provides a transparent regulatory environment. With a robust financial ecosystem of over 17,000 fund professionals specializing in fund administration, depositary, legal, and tax services, Ireland is recognised as a top-tier fund servicing destination.
Europe’s Fastest-Growing Fund Domicile
Ireland is the fastest-growing major European fund domicile, managing nearly 20% of all European fund assets. This is bolstered by the jewel in Ireland’s crown: Ireland’s ILP, reformed in 2021. The ILP offers several advantages for U.S. asset managers. Given its Alternative Investment Fund Managers Directive (AIFMD) compliant structure, tax transparency, and regulatory credibility, it is a strong alternative to Luxembourg’s Special Limited Partnership (SCSp) or Cayman funds for European and global investors:
- Tax Efficiency: tax-transparent, with no corporate, capital gains, or withholding tax for non-Irish investors, and benefits from Ireland’s extensive double tax treaty network for favorable tax treatment. The income, gains, and losses of an ILP are allocated to each limited partner (LP) based on their proportional ownership in the partnership.
- Competitive Alternative to Luxembourg’s SCSp: offers lower regulatory costs, faster approval times, and a common law legal system that aligns more closely with U.S. investors.
- Flexibility in Fund Structuring: offers an umbrella structure with segregated liability, flexible capital commitments for various fund types, and LP-friendly governance that allows advisory participation without compromising limited liability.
- Suitable for Multiple Alternative Strategies: It mirrors the structure of U.S. LPs and offers tax transparency, governance flexibility, a robust legal framework for asset holding and lending, long-term investment suitability, and adaptability for both liquid and illiquid strategies.
- Streamlined Regulatory Process: 24-hour approval for Qualifying Investor Alternative Investment Funds (QIAIFs) and no pre-approval requirements for general partners (GPs). The GP can be based outside Ireland and does not have to be a corporate entity.
The Growing Trend
According to ISS Market Intelligence, assets under management (AUM) by U.S. asset managers in Europe more than doubled in a decade, from $2.1 trillion in 2014 to $4.5 trillion as of September 2024. The numbers are clear. U.S. asset managers are increasingly turning to Europe to diversify their investor base and tap into the region’s deep pools of capital. And Ireland is increasingly the domicile of choice.
Contact Us
If you would like to gain deeper insights into this area and explore how it may impact your business, we invite you to connect with Paul Traynor, Partner and Head of Governance, Risk, and Compliance.
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EisnerAmper Ireland Welcomes TY Students for an Immersive Work Experience Programme
We had the pleasure of welcoming talented transition year (TY) students to our ‘EAI for TY’ Work Experience Programme 2025 in the week of 10th February 2025.
This programme provided students with a unique opportunity to step into the world of professional services and gain first-hand experience across a range of business functions. Through interactive, engaging presentations, and department rotations, students explored key areas of our firm, including audit, tax, accounting, EA Solve, Governance, Risk & Compliance, HR and Operations.
A Week of Learning & Growth
Throughout the program, the students met with Partners and took part in a series of in-depth presentations led by experienced professionals from across our firm. These sessions provided valuable insights into the business landscape, including:
EisnerAmper Ireland, the story to date – A deep dive into the Firm’s origins, growth, and role in the Global EisnerAmper network, highlighting our commitment to excellence and innovation in professional services.
Information Management Systems & GDPR – An introduction to data security and best practices for managing information within a business environment, emphasising the importance of data protection and regulatory adherence.
Cybersecurity – A practical session on identifying and mitigating cyber threats, covering real world case studies and essential tips on staying secure in the digital age.
Risk & Quality – An overview of risk management strategies, quality control processes, and how businesses safeguard their operations against potential threats.
Commercial Awareness – An interactive session focusing on an understanding of economic trends, industry developments, and the key drivers of business success.
In addition, students participated in hands– on workshops designed to develop critical professional skills, including
Presentation Skills – A practical workshop focused on effective communication, public speaking techniques and building confidence when delivering presentations.
CV & Interview Skills – A comprehensive session on crafting a professional CV, preparing for job interviews mastering and mastering techniques to make a strong impression in the hiring process.
The team Project Challenge
The highlight of the week was the team project challenge, giving students the opportunity to collaborate in small groups to apply their learnings from the program. Guided by mentors from EisnerAmper Ireland, each team worked on a business-related challenge, developing strategic solutions and presenting their findings to a panel of EisnerAmper Ireland Partners on the final day. This challenge provided students with a unique opportunity to showcase their creativity, problem solving abilities, and teamwork skills while receiving valuable feedback from industry professionals.
Looking Ahead
We are proud to support the next generation of professionals by providing meaningful learning experiences that inspire and empower young talent. If you are a Transition Year Student and interested in joining our next programme, please contact us at hr@eisneramper.ie.
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