Yes - I'm also in the asset management industry. The ultimate point is, investors in a fund don't want to end up in a worse tax position than if they'd made the

Yes - I'm also in the asset management industry. The ultimate point is, investors in a fund don't want to end up in a worse tax position than if they'd made the investments in the fund directly and not via a fund. The worst of all worlds are paying tax at the fund level and not being able to offset that against local tax due - this is surprisingly more common than you might think; not to mention tax-exempt investors like some pension funds (sovereign wealth funds are a bit different again). Some jurisdictions for fund tax residence/incorporation are much much better for this than others. If you then also look at jurisdictions which have a predictable and fair legal system and an efficient admin setup for funds you end up with quite a short list of places (Cayman, Luxembourg, Ireland, etc).