Open Closed-Ended Investment Funds in Spain: Legal & Regulatory Guide

Introduction: Spain’s Investment Fund Landscape

Spain is a major European hub for regulated investment funds, offering flexibility through both open-ended funds (fondos de inversión) and closed-ended funds (sociedades de capital riesgo and sociedades de inversión).

At Borderless Lawyers, we assist asset managers, fund sponsors, and international investors in setting up compliant, tax-optimized structures in Spain’s regulated financial environment.


🏦 Understanding Open vs. Closed-Ended Funds

🔓 Open-Ended Funds (Fondos de Inversión)

  • Investors can subscribe or redeem shares at any time based on NAV (Net Asset Value).

  • Managed by a fund management company (SGIIC) under CNMV oversight.

  • Assets can include equities, fixed income, money markets, or mixed portfolios.

  • Popular among retail and institutional investors.

📌 Must be registered with the CNMV (Comisión Nacional del Mercado de Valores) before public offering.

🔒 Closed-Ended Funds

These include:

  • Sociedades de Capital Riesgo (SCR): Focus on private equity or venture capital investments.

  • Sociedades de Inversión de Capital Variable (SICAV): Specialized tax-efficient vehicles, typically for high-net-worth individuals.

Key features:

  • Investors typically cannot redeem shares on demand.

  • More suitable for long-term investment strategies.

  • Regulated under Spain’s Law 22/2014 on venture capital and closed-ended vehicles.

⚠️ Closed-ended funds are often subject to minimum capital and investor requirements.


📝 Legal Requirements to Set Up a Fund

✅ General Setup Process

  1. Select Structure: Open-ended (Fund/SICAV) or Closed-ended (SCR).

  2. Draft Bylaws & Prospectus: Define investment policy, risks, redemption terms, and governance.

  3. Appoint Key Roles: Fund manager (SGIIC), depositary entity (custodian), and auditors.

  4. Register with CNMV: Submit all required legal documents and obtain approval.

  5. Tax Registration & NIF: Obtain a Spanish tax ID and register for applicable tax regimes.

📈 Minimum Capital

  • Open-ended: Typically €3 million minimum.

  • SCRs: Minimum €1.2 million (can vary depending on investor type).

  • SICAVs: €2.4 million minimum capital and 100 shareholders (minimum requirement).


💶 Taxation & Regulatory Oversight

⚖️ CNMV Supervision

All funds are regulated by the CNMV, ensuring:

  • Investor protection

  • Transparency and reporting obligations

  • Anti-money laundering compliance

🧾 Tax Regimes

  • Most funds enjoy favorable tax deferral or reduced tax rates.

  • SICAVs previously had a 1% tax rate, but stricter investor requirements now apply.

  • Funds must file regular tax declarations and financial statements.

🛡️ Borderless Lawyers works with accountants and tax advisors to ensure full compliance.


🌍 Why Foreign Investors Use Spanish Funds

  • EU-passporting and MiFID II harmonization

  • Access to European capital markets

  • Clear legal protections for investors

  • Favorable tax treatment (depending on structure)

  • Efficient administration for cross-border asset managers

🔐 For non-EU investors, Spain can act as a gateway jurisdiction for European fund distribution.


🧑‍💼 How We Can Help

Our team at Borderless Lawyers provides:

  • 📑 Legal structuring and CNMV filings

  • 🔍 Due diligence on proposed fund strategies

  • 📊 Coordination with tax advisors and financial entities

  • 📈 Ongoing compliance and governance support


📞 Ready to Launch a Fund in Spain?

Whether you’re structuring a UCITS-like vehicle or a private capital SCR, Borderless Lawyers helps you navigate the full legal and regulatory process in Spain.

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