Jersey Private Funds for Singaporean real estate investment managers

How can Singaporean real estate investment managers efficiently access UK and European property markets? Jersey Private Funds (JPFs) offer a streamlined, flexible solution with strong regulatory support, making them an increasingly popular choice for cross-border investment. 

Singapore and the UK's living sector 

While transactional volumes across the broader real estate asset class continue to remain comparatively subdued, the UK's 'living sector' appears to have weathered the worst of the recent economic storm and investment continues to flow. Significantly, a large portion of this capital, based on our deal visibility, has been (and continues to be) driven by Singaporean private equity real estate fund managers. From large Singapore headquartered alternative private equity institutions, to newer market entrants driven by the recent growth boom in Singapore's single family office market, European real estate assets continue to diversify the portfolios of Singaporean investors. 

As advisers and agents of Singapore domiciled managers investing in European real estate through Jersey and UK special purpose holding vehicles, we can see the appeal: inflation control after a period of rate explosion, the prospect of more affordable debt on the horizon, the performance of the SGD against the GBP in recent years, the 'green shoots' of a wider market recovery (and US trade deals) and the sustained demand (and chronic under supply) of residential stock on the market. 

In addition, while there are differences in cultures and investment frameworks, Singapore and the UK share a number of core framework similarities. For example, both operate frameworks with freehold and leasehold property ownership concepts (although leasehold dominates the market in Singapore), and share similar tax concepts, such as stamp duty on property. Familiarity of key property ownership concepts is helpful. 

Whether the pursuit of land development opportunities or the targeting of existing operational stock, Singaporean capital continues to flood the UK's purpose-built student accommodation (PBSA) market. According to a February 2025 Knight Frank publication, 2024 was a record year for PBSA transactional volumes in the UK and, despite the development pipeline delay issues caused by the Building Safety Act Gateways, the fundamentals of the UK's PBSA market appear to remain attractive to Singaporean capital. Particularly, those looking at PBSA opportunities across Russell Group university cities in the UK. 

Structuring: what we are seeing 

While a one-size-fits-all approach seldom works for tax planning and structuring, technical advisers considering local Singaporean managers and their investment in European real estate assets frequently recommend the Jersey limited partnership (JLP) structure, particularly when it comes to investment in the UK. We regularly hear Singaporean managers citing Jersey's strong legal framework, political stability, transparency, tax neutrality and support options from local third-party specialists such as Ogier, as factors encouraging their investment platform. 

A Jersey limited partnership fund will typically be regulated under the Jersey Private Fund (JPF) regime. The JPF's light-touch regulation, speed and ease to market, versatility and, importantly, its ongoing administration costs make it attractive option on the global fund type menu for Singaporean managers. 

A large proportion of the Singaporean manager-led real estate fund deals to have crossed our desks in recent years share very similar characteristics. Broadly, they can be visualised as a Jersey fund vehicle (typically a limited partnership, regulated as a JPF, as mentioned above) acting as the pooling vehicle for the Singaporean investors' capital, under which sits a 'downstream' structure of Jersey or UK incorporated private limited companies – carrying out holding company, financing company, operating company, or property holding company activities, depending on the nature of the asset. Holding companies are frequently incorporated in Jersey to take advantage of Jersey's more flexible corporate law regime, but often resident in the UK, based on tax advice. 

The holding of European real estate investments, by Singaporean domiciled managers, in Jersey and UK corporate structures does generally come with the need to appoint local support in the form of third-party administration specialists. These third-party regulated specialists, such as Ogier, work closely with the Singaporean manager to take care of the day-to-day running of the structure – from financial reporting, compliance services, investor services, governance services and cash management.  Read more about our Real Estate Fund services. 

Why the Jersey Private Fund? 

The JPF has been a tremendously popular fund product since its introduction in 2017 and has become increasingly familiar to Singaporean managers and investors. It continues to be the popular choice, because:  

• a JPF can take various legal forms, the most common being limited partnership, limited companies and unit trusts  
• the JPF guide is light-touch, providing flexibility for the terms of the fund 
• a JPF may be open or closed-ended 
• there is no requirement for the JPF to appoint an auditor, which provides cost efficiency against other fund products on the market 
• there is no explicit requirement for the governing body of the JPF to be managed and controlled in Jersey, although the regulator does expect at least one or more Jersey resident directors to be appointed. This facilitates client involvement at JPF board decision making level, and mixed boards (client and third-party Jersey administrator balanced) are common practice 
• a JPF must appoint a Jersey based designated service provider (DSP) (such as Ogier), who carries out the appropriate due diligence on the fund and its investors.  As a result of reliance placed on this DSP, the regulator applies a lighter touch regulatory framework on the JPF – essentially regulating it indirectly via the DSP (in addition to AML supervision) 
• a JPF can be marketed effectively into the United Kingdom and European Union via national private placement regimes, subject to limited additional filings under Jersey's alternative investment fund managers directive (AIFMD) regulation 
• a JPF can obtain authorisation from the regulator in as little as 24 hours, following a streamlined application process, offering speed to market for managers 

How can Ogier help?

Based in Jersey, Ogier's legal and real estate fund administration teams collaborate seamlessly to support Singaporean fund managers investing in UK and European real estate throughout the lifecycle of their investment. Ogier can support from legal and regulatory advice at fund launch, through to the on-going governance, compliance and day-to-day administration of the Jersey and UK vehicle structure. 

To find out more about our integrated real estate service offering, contact a member of our team.  

About Ogier

Ogier is a professional services firm with the knowledge and expertise to handle the most demanding and complex transactions and provide expert, efficient and cost-effective services to all our clients. We regularly win awards for the quality of our client service, our work and our people.

Disclaimer

This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.

Regulatory information can be found under Legal Notice