SPV jurisdiction comparator
Singapore, Cayman, BVI or Delaware — answer a few questions about your investors and priorities, and see which jurisdiction fits your single-deal SPV, with a full side-by-side comparison.
- Singapore gives you a well-regulated, bank-friendly base with growing recognition among Asia-based LPs.
| Singapore | Cayman | BVI | Delaware | |
|---|---|---|---|---|
| Formation speed | 3–7 days — ACRA approval is often same-day | 3–5 days via a registered agent | 2–4 days — usually the fastest to incorporate | Same day to 2 days via a formation agent |
| Typical setup cost | Lowest of the four for a simple, single-asset SPV | Mid-to-high — government and agent fees add up | Mid — cheaper than Cayman for a similar structure | Lowest state fees, offset by US tax return costs |
| Ongoing entity-level tax | 17% corporate tax, often minimal on a pure holding SPV | Zero corporate, capital gains or withholding tax | Zero corporate, capital gains or withholding tax | Pass-through — no entity tax, but annual US information returns for foreign owners |
| Investor familiarity | Growing recognition, strongest with Asia-based LPs | The market-standard wrapper for institutional and tax-exempt LPs | Familiar as a lighter-weight Cayman alternative | Most familiar to US taxable investors used to K-1 reporting |
| Ease of opening a bank account | Straightforward with an established local bank presence | Slower — offshore KYC is heavier | Slower — similar offshore KYC burden to Cayman | Fast via fintech providers if directors/members are US-based |
| Public disclosure | Directors & shareholders appear on ACRA's public register | No public register of directors or shareholders | No public register of directors or shareholders | No public member list at the state level |
| Statutory audit requirement | Exempt if the entity meets the small-company criteria | Not required unless a regulator, lender or investor asks | Not required unless a regulator, lender or investor asks | Not required by the state, though lenders may still ask |
| Substance / annual filings | Standard ACRA annual return and tax filing only | Economic substance notification for relevant activities | Economic substance and beneficial ownership (BOSS) filing | Federal beneficial ownership report; no state-level substance test |
Educational guidance, not legal or tax advice — confirm structuring with your fund counsel before forming an SPV in any jurisdiction. Built by aama.io.
About this tool
A special purpose vehicle (SPV) is a single-purpose entity set up to hold one deal — a co-investment, a real estate asset or a syndicated round — separately from a fund's main portfolio. The right jurisdiction depends on who is investing, how fast you need to move, and how much privacy and tax neutrality matter relative to cost.
This comparator weighs your investor base and priorities against four common SPV jurisdictions — Singapore, Cayman Islands, BVI and Delaware — and recommends the one that fits, with a full side-by-side on cost, speed, tax, banking and disclosure.
How to use it
- Tell the tool about your investor base — US taxable individuals, institutional or tax-exempt LPs — and how quickly you need an Asia-based bank account.
- Flag whether privacy (no public register) or cost is your top priority.
- Read the recommended jurisdiction, fit confidence and the full four-way comparison matrix.
Frequently asked questions
What is a single-deal SPV used for?
A single-deal special purpose vehicle holds one investment — a co-investment alongside a lead fund, a real estate asset, or a syndicated round — ring-fencing that deal's assets and liabilities from a manager's other funds and giving each investor a clean, deal-specific vehicle to invest through.
Which jurisdiction is best for an SPV: Singapore, Cayman, BVI or Delaware?
It depends on the investor base. Cayman is the market-standard choice for institutional and tax-exempt LPs; Delaware suits a mostly US taxable investor base familiar with K-1 reporting; Singapore is strongest when you need fast, local Asia banking; BVI offers the same tax-neutral, private structure as Cayman at a lower ongoing cost.
Do Cayman and BVI SPVs pay any tax?
No — both charge zero corporate income, capital gains or withholding tax at the entity level. The cost of using them is entirely in formation and administration fees, not tax, and both require an annual economic substance and beneficial-ownership filing.
Is a Delaware LLC taxed at the entity level?
By default, no — a Delaware LLC is a pass-through entity for US federal tax purposes. However, non-US owners of a foreign-owned disregarded LLC must still file annual US information returns (such as Form 5472), even though no US tax is typically due.