Managing cross-border SPV structures

Why scalable operating models are becoming the next competitive advantage

Managing cross-border SPV structures
  • September 08, 2026

Private markets continue to grow in scale and complexity, with asset managers expanding across private equity, private credit, real estate and infrastructure. As investment platforms become increasingly international, cross-border Special Purpose Vehicles (SPVs) are playing a central role in supporting investment strategies and facilitating capital deployment across jurisdictions. 

 

At the same time, the operational environment surrounding these structures is changing rapidly. Investors are demanding greater transparency and more timely reporting, while regulatory expectations continue to evolve across jurisdictions. As portfolios expand and structures become more interconnected, firms are increasingly challenged to maintain consistency, governance and operational efficiency at scale.

 

The question is therefore no longer whether organisations can build sophisticated investment structures, but whether their operating models can continue to scale alongside them.

USD 26.6T

Global private market assets under management are projected to reach USD 26.6 trillion by 2030.

PwC Asset & Wealth Management Revolution 2025
13,180

SCSps registered in Luxembourg by 2025, highlighting the continued expansion of private market structures

PwC Global AWM & ESG Research Centre, CSSF, LBR
3,181

RAIF structures recorded in Luxembourg by 2025.

PwC Global AWM & ESG Research Centre, CSSF, LBR

The changing landscape of private market structures

Luxembourg's private markets ecosystem reflects a broader evolution taking place across the asset and wealth management industry. Over the last decade, the number of structures has increased significantly, illustrating how investment platforms have become larger, more sophisticated and operationally more intensive.

While SPVs continue to perform their traditional role within investment structures, the environment in which they operate has become considerably more demanding. Modern private market strategies increasingly involve interconnected networks of holding companies, financing vehicles and SPVs across multiple jurisdictions, creating new challenges around governance, reporting and compliance across a broader operational ecosystem.

This growing interconnectedness means asset managers are managing far more than individual entities. They are coordinating structures where decisions taken in one jurisdiction can have implications across several others, fundamentally changing the nature of SPV management.

Activity has instead shifted towards the existing population of vehicles, with asset managers reviewing their arrangements with incumbent service providers in growing numbers. Indeed, the market for migrating existing SPVs to a new service provider is unusually active, and for the latter, this reshapes where the commercial opportunity lies, placing a premium on the ability to onboard and migrate structures smoothly.

Four pressures testing existing operating models

For many years, operating models evolved alongside business growth. As asset managers expanded into new markets, launched new funds and established increasingly sophisticated structures, operational capabilities generally grew through additional capacity, local expertise and incremental process improvements. Today, however, the operating environment is fundamentally different.

Asset managers are increasingly facing pressure across four dimensions: entity growth, regulatory expectations, investor expectations and scalability constraints. Larger and more interconnected SPV ecosystems require greater coordination and oversight, while evolving regulatory requirements, rising expectations around transparency and reporting, and ongoing resource pressures are making operating models harder to sustain at scale.

Thus, operational demands are increasing exponentially rather than incrementally. Sustainable growth therefore depends on operating models that can absorb additional scale without requiring a proportional increase in resources, while maintaining consistent service quality and a cost-effective delivery model.

Key priorities for asset managers

Growth should not require organisations to redesign their operating model every time they launch a new fund, enter a new jurisdiction or establish additional SPVs. Instead, operating models should be built around standardised processes, integrated governance and flexible delivery capabilities that enable organisations to absorb increasing scale without a proportional increase in operational effort, cost or complexity.

As SPVs become more interconnected, consistency becomes an existential imperative. Standardised governance frameworks, integrated data and technology-enabled workflows help organisations improve transparency, strengthen operational resilience and deliver more consistent reporting across legal entities and jurisdictions.

Technology plays a critical role in this transformation, but its greatest value is realised when it supports well-designed operating models rather than attempting to compensate for fragmented processes or inconsistent governance.

The growing sophistication of cross-border SPV structures is changing how organisations access operational capabilities.

Rather than relying solely on internal expansion, leading asset managers are factoring in the combination of internal leadership, specialist external expertise and technology-enabled delivery to create more flexible operating ecosystems.

This approach enables organisations to respond more effectively to growth, regulatory change and evolving investor expectations while maintaining governance, control and operational resilience.

With much of today’s activity centred on transferring existing structures between service providers, the ability to onboard and migrate SPVs efficiently has become a priority in its own right.

When selecting and working with service providers, asset managers should look for proven migration methodologies that protect business continuity, preserve data integrity and limit the demands placed on internal teams during the transition, supported by the geographical coverage and combined accounting and tax expertise needed to sustain quality and consistency thereafter.

Managing cross-border SPV structures

Explore our perspective on the operational, governance and delivery considerations shaping cross-border SPV management.

Contact us

Alexandre Igel

Accounting Partner, Managed Services Client & Market, PwC Luxembourg

Tel: +352 62133 54 73

Björn Ebert

Financial Services and Managed Services Leader, PwC Luxembourg

Tel: +325 621 332 256

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