In certain cases with lower amounts (< 100m€), it might make sense to set up an unlicensed trust fund in
Estonia (registered with Financial Supervision Authority). Cheap and quick setup with full confidentiality to investors. Ability to manage stocks, derivatives,
cryptocurrencies, real estate, and other financial assets and commodities.
For this setup, two entities need to be created - fund manager (Estonian LLC) and trust fund (LPF).
Fund Manager´s main activity is the management of one or more funds, i.e. the management of financial assets of investors in order to maximize profits with minimal risk. Small Fund Manager has the right to control several funds, but the total assets of the managed funds cannot exceed
100 million euros, or in case if the
investments are made for long periods (from 5 years or more) and financial leverage (income gearing) is not used, then the total assets of the funds can reach 500 million euros.
Limited Partnership Fund (LPF)
is easy to register and manage, being the most common legal form for the Small Alternative Investment Fund.
The members of LPF are at least one General Partner (Fund manager-registered in Estonia), and at least one Limited Partner, i.e. investor (can be foreign entities).
LPF is fiscally transparent meaning that LPF is not considered a taxpayer or an Estonian resident for the purposes of Estonian tax laws, and the income earned by LPF is immediately allocated to its investors in proportion to their stakes in LPFs.
The investors will be then taxed as if they made investments directly, i.e., they will retain access to DTT-s.
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