IFM08220 - Co-ownership Authorised Contractual Schemes (CoACS): Information requirements: Providing information to investors

What information must be provided?

Under regulation 4 of SI 2017/1209, the operator of a CoACS must provide investors with sufficient information to fulfil their tax obligations. The requirement is intended to be flexible depending on the information needs of the investors. HMRC expects that the operator of a CoACS will notify investors of:

  • The amount of income which has arisen to them during a period of account;
  • The amount of any deductible expenses allocated to them;
  • The amount of any capital allowance allocated to them; and
  • Such amounts and other adjustments which would enable an investor to calculate the chargeable gain on disposal of units in the CoACS.

Other information may be required by an investor depending on their circumstances.

As with providing information to investors, the operator of a CoACS (C1) must also provide sufficient information to the operator of another CoACS (C2) if it has invested in C1. This enables C2 to make a proper report to its own investors. See regulation 5 of SI 2017/1209.

Further detail as regards capital allowances and income arising in offshore funds is outlined at IFM08300.

Information relating to income

Investors in a CoACS who are within the charge to UK tax will require details of the type of income received, such as any income from property, dividend income, interest receivable and so on. This will include details of any income that has had tax withheld.

Investors who are exempt from UK taxation may require less information for UK tax purposes (although they may still need to complete a tax return depending on their circumstances). The information required by overseas investors will depend on the tax treatment of income and gains in the jurisdiction in which they are resident.

The Government’s consultation on bringing non-residents within charge to tax on gains on UK property with effect from April 2019 has now closed and officials are currently working on the detail of the rules regarding collective investment vehicles. Draft guidance was published in December 2018.

When information must be provided to investors

The operator must provide required information to investors by the “information reporting date”, which is the date six months after the end of the period of account of the CoACS – see regulation 3 of SI 2017/1209.

It has been suggested to HMRC that certain information, such as capital allowances, may not be available by that date. HMRC will keep this under review in consultation with stakeholders.