Updates: Investment Funds Manual

2024

2 December 2024

Overview: Commencement

Updated to reflect recent case law

14 November 2024

Prevention of double taxation: Double taxation relief and trusts

Page updated to make meaning clearer and now with an example.

4 October 2024

Other tax issues: contents

IFM40695 - whether investments are non-commercial securities - added to relevant contents page

2 August 2024

Genuine Diversity of Ownership (GDO): Condition A

Update to clarify that, in the case of the QAHC regime, it is sufficient that the fund was marketed at any time before 1 April 2022. It is not necessary that the marketing was completed before that date.

30 May 2024

Real Estate Investment Trust : Entry to the regime: effects of entry: deemed sale and reacquisition of assets: CTA2010/S536

Link to CG14270 changed to CG14250P

14 May 2024

Foreign Chargeable Gains: Introduction

Whole page updated.

29 April 2024

Charging Provisions: Operation of the charge: Relief for payments to acquire rights to carried interest

Whole page updated

19 January 2024

Becoming a QAHC: apportionment of income and expenses across ring fence

Change to ensure that guidance is consistent with underlying legislation (specifically, FA22/SCH2/PARAS 20(1)(c)).

Becoming a QAHC: ring fence business

Change to ensure that guidance is consistent with underlying legislation (specifically, FA22/SCH2/PARAS 20(1)(c)).

2023

6 November 2023

Introduction to Investment Funds Manual

Short Name Updated

Property authorised investment funds (PAIFs)

Short Name Updated

Taxation of investment trusts

Short Name updated

1 November 2023

Overview: Charging provisions and capital gains tax rate

Improving the text to aid understanding of the reader.

27 September 2023

Accruals basis elections: reporting

Corrected formatting error.

26 September 2023

Accruals basis elections: reporting

Update changes following review

19 July 2023

Accruals basis elections: contents

update changes following review

Carried interest: Contents

update changes following review

18 July 2023

Administrative requirements: entry notifications

Updated to clarify position where agent is acting on behalf of client

Carried interest: Contents

update changes following review

13 July 2023

Eligibility criteria: election to treat listed securities as unlisted

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

12 July 2023

When does a genuine diversity of ownership (GDO) condition apply?

Updates following the enactment of Finance (No.2) Act 2023.

Genuine Diversity of Ownership (GDO)

Updates following enactment of Finance (No.2) Act 2023

Specific provisions relating to feeder funds

Updates following enactment of Finance (No.2) Act 2023

Eligibility criteria: introduction

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

Eligibility criteria: ownership condition: introduction

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

Eligibility criteria: ownership condition: FA22/SCH2/PARA4

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

Eligibility criteria: category A investors: meaning

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

Eligibility criteria: category A investors: examples

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

Eligibility criteria: category A investors: further provisions

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

Eligibility criteria: compliance with ownership condition

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

Eligibility criteria: investment strategy condition

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

Eligibility criteria: contents

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

Other tax issues: corporate interest restriction: non-consolidation of certain subsidiaries

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

Treatment of certain payments : contents

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

Gains exemption: qualifying shares

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

Administrative requirements: entry notifications

Guidance updated to provide clarity and to reflect changes made by the Finance (No.2) Act 2023.

5 April 2023

Genuine Diversity of Ownership (GDO): Introduction

Updates following review

Updates following review

Updated following review

When does a genuine diversity of ownership (GDO) condition apply?

Updates following review

Genuine Diversity of Ownership (GDO): Conditions

Update following review

Specific provisions relating to feeder funds

Updates following review

Genuine Diversity of Ownership (GDO): advance clearance procedure: Introduction

Updates following review

Updates following review

Genuine Diversity of Ownership (GDO): advance clearance procedure: Application

Updates following review

Genuine Diversity of Ownership (GDO): advance clearance procedure: Relying on clearance

Updates following review

Genuine Diversity of Ownership (GDO): Condition B

Updates following review

Updates following review

Condition C: Marketing requirements

Updates following review

Updates following review

Condition C: Investors requesting information

Updates following review

Updates following review

Condition C: Limit on capacity to receive further investments

Updates following review

Updates following review

Genuine Diversity of Ownership (GDO)

Updates following review

Updates following review

Updates following review

Authorised investment funds (AIFs): qualified investor schemes (QISs) and long-term asset funds (LTAFs): tax and the genuine diversity of ownership condition

Updates following review

Updates following review

Offshore Funds: Reporting Funds: computation of reportable income: transactions not treated as trading: conditions

Updates following review

Genuine Diversity of Ownership (GDO): Condition C

Updates following review

Updates following review

Particular considerations relating to closed-ended funds

Updates following review

Genuine Diversity of Ownership (GDO): advance clearance procedure

Updates following review

Genuine Diversity of Ownership (GDO): Condition A

Updates following review

Checking Condition C

Page archived

28 February 2023

Real Estate Investment Trust : Miscellaneous: indirect ownership of property: non-resident unit trusts

Links to other pages corrected

12 January 2023

Investment transactions – the ‘investment transactions list’

Updating guidance to take account of the Investment Manager (Investment Transactions) (Cryptoassets) Regulations 2022 to add “designated cryptoassets” to the investment transaction list for the purposes of the Investment Manager Exemption

Authorised investment funds (AIFs): taxation of investors within the charge to CT: dividend distributions

Correcting an error by removing the words "enable exempt investors to receive a credit for tax paid within the AIF" and instead making clear that exempt investors are unable to reclaim tax paid within the AIF

2022

24 October 2022

Overview: Policy Background

update changes following review.

27 July 2022

Genuine Diversity of Ownership (GDO): Introduction

update changes following review.

When does a genuine diversity of ownership (GDO) condition apply?

Update changes following review.

29 June 2022

Eligibility criteria: activity condition

Update changes following review.

Eligibility criteria: category A investors: further provisions

Update changes following review.

6 June 2022

Eligibility criteria: trade versus investment

Update changes following review

31 May 2022

Eligibility criteria: compliance with ownership condition

Update changes following review.

Becoming a QAHC: example of ring fence streaming within QAHC

Update changes following review.

12 April 2022

Other tax issues: exchange gains

update changes following review

update changes following review

Update changes following review.

16 March 2022

Eligibility criteria: ownership condition: examples

Update changes following review.

Eligibility criteria: ownership condition: further examples

Update changes following review.

9 March 2022

Eligibility criteria: trade versus investment

Update changes following review

Eligibility criteria: contents

update changes following review

7 March 2022

Qualifying Asset Holding Companies: contents

update changes following review

Update changes following review

Update changes following review.

Update changes following review.

Eligibility criteria: contents

Update changes following review

Becoming a QAHC: contents

Update changes following review.

Ceasing to be a QAHC: contents

Update changes following review.

Group issues: contents

Update changes following review.

Other tax issues: contents

Update changes following review.

Treatment of certain payments : contents

Update changes following review.

Overseas property business: contents

Update changes following review.

Gains exemption: contents

Update changes following review.

Remittance basis: contents

Update changes following review.

Stamp duty and SDRT: contents

Update changes following review.

Administrative requirements: information to be provided: contents

Update changes following review.

Administrative requirements: non-deliberate breach of ownership condition: contents

Update changes following review.

Administrative requirements: contents

Update changes following review.

4 March 2022

Overview: Introduction

update changes following review

Overview: Policy Background

update changes following review

Overview: A short guide

update changes following review

Overview: structure of the legislation

update changes following review

Overview: contents

update changes following review

Eligibility criteria: introduction

update changes following review

Eligibility criteria: ownership condition: introduction

update changes following review

Eligibility criteria: ownership condition: FA22/SCH2/PARA3

update changes following review

Eligibility criteria: ownership condition: FA22/SCH2/PARA4

Update changes following review.

Eligibility criteria: ownership condition: FA22/SCH2/PARAS 5 to 7

Update changes following review.

Eligibility criteria: ownership condition: examples

Update changes following review.

Eligibility criteria: ownership condition: further examples

Update changes following review.

Update changes following review.

Eligibility criteria: category A investors: meaning

Update changes following review.

Eligibility criteria: category A investors: examples

Update changes following review.

Eligibility criteria: category A investors: further provisions

Update changes following review.

Eligibility criteria: compliance with ownership condition

Update changes following review.

Eligibility criteria: activity condition

Update changes following review.

Eligibility criteria: trade versus investment

Update changes following review.

Eligibility criteria: investment strategy condition

Update changes following review.

Eligibility criteria: contents

Update changes following review.

Update changes following review.

Becoming a QAHC: contents

Update changes following review.

Update changes following review.

Ceasing to be a QAHC: contents

Update changes following review.

Update changes following review.

Group issues: contents

Update changes following review.

Update changes following review.

Other tax issues: contents

Update changes following review.

Update changes following review.

Treatment of certain payments : contents

Update changes following review.

Update changes following review.

Overseas property business: contents

Update changes following review.

Update changes following review.

Gains exemption: contents

Update changes following review.

Update changes following review.

Remittance basis: contents

Update changes following review.

Update changes following review.

Stamp duty and SDRT: contents

Update changes following review.

Update changes following review.

Administrative requirements: contents

Update changes following review.

Update changes following review.

Administrative requirements: information to be provided: contents

Update changes following review.

Administrative requirements: non-deliberate breach of ownership condition: contents

Update changes following review.

Ceasing to be a QAHC: breaches of eligibility criteria

Update changes following review.

Other tax issues: introduction

Update changes following review.

Treatment of certain payments: introduction

Update changes following review.

Administrative requirements: breaches of eligibility criteria (except the activity and ownership condition)

Update changes following review.

Administrative requirements: breach of ownership condition: wind-down period

Update changes following review.

Becoming a QAHC: interaction with loss restriction

Update changes following review.

Update changes following review.

Remittance basis: calculating the foreign proportion of income and gains

Update changes following review.

Update changes following review.

Administrative requirements: information to be provided: QAHC information return

Update changes following review.

Qualifying Asset Holding Companies: contents

Update changes following review.

Remittance basis: interaction with mixed fund rules

Update changes following review.

3 March 2022

Eligibility criteria: ownership condition: examples

Update changes following review

Update changes following review

Update changes following review

Eligibility criteria: ownership condition: further examples

Update changes following review

19 January 2022

Prevention of double taxation: Introduction

update change following review

update changes following review

13 January 2022

Prevention of double taxation: Introduction

Update changes following review

Prevention of double taxation: Non-UK tax

Delaying publication until further review. Archiving reason text added. Page archived.

2021

8 December 2021

Investment transactions – the ‘investment transactions list’

Updating terminology

Updating terminology

Updating terminology

Authorised investment funds (AIFs): general

Amendments to reflect changes to UCITS schemes and the introduction of Long-Term Asset Funds.

Authorised investment funds (AIFs): qualified investor schemes (QISs) and long-term asset funds (LTAFs): introduction

Change to incorporate guidance for long-term asset funds.

Authorised investment funds (AIFs): qualified investor schemes (QISs) and long-term asset funds (LTAFs): tax and the genuine diversity of ownership condition

Changes to incorporate guidance for long-term asset funds.

Authorised investment funds (AIFs): qualified investor schemes (QISs) and long-term asset funds (LTAFs): consequences of breaching the genuine diversity of ownership (GDO) condition

Changes to incorporate guidance for long-term asset funds.

Taxation of authorised investment funds (AIFs): qualified investor schemes (QISs) and long-term asset funds (LTAFs)

Change to incorporate guidance for long-term asset funds

Tax treatment of investors in qualified investor schemes (QISs) and long-term asset funds (LTAFs): Basic position

Changes to incorporate guidance for long-term asset funds.

Tax treatment of investors in qualified investor schemes (QISs) and long-term asset funds (LTAFs): consequences if the genuine diversity of ownership condition is breached

Changes to incorporate guidance for long-term asset funds.

When does a genuine diversity of ownership (GDO) condition apply?

Changes to incorporate guidance for long-term asset funds.

Tax treatment of investors in qualified investor schemes (QISs) and long-term asset funds (LTAFs)

Changes to incorporate guidance for long-term asset funds

Authorised investment funds (AIFs): taxation of funds: investment transactions

Updating terminology

Exempt unauthorised unit trust (EUUT): Income

Updating terminology

Offshore Funds: Reporting Funds: computation of reportable income: transactions not treated as trading: conditions

Updating terminology

Offshore Funds: Reporting Funds: computation of reportable income: transactions not treated as trading: introduction

Updating terminology

23 September 2021

Carried interest and profit related returns: Contents

update changes following review

update change following review

22 September 2021

Carried interest and profit related returns: Contents

update changes following review

21 September 2021

Carried interest and profit related returns: Tax Distributions

Updated text for accuracy.

20 September 2021

Disguised fees: Managed Accounts and other parallel structures (from 6 April 2016)

update changes following review

update changes following review

Disguised fees: Managed Accounts and other parallel structures (from 6 April 2016): Managed accounts

update changes following review

update changes following review

14 September 2021

Prevention of double taxation: Double taxation adjustment

update changes following review

2020

13 October 2020

Overview: Contents

update changes following review

12 October 2020

Disguised fees: Contents

update changes following review

2 October 2020

Disguised fees: Condition 2 (sums arising on or after 6 April 2015 and before 22 October 2015) - A management fee arising to the individual: Sums arising "directly or indirectly"

update changes following review

Disguised fees: Condition 2 (sums arising on or after 6 April 2015 and before 22 October 2015) - A management fee arising to the individual: Sums arising from 'loans and advances'

update changes following review

Disguised fees: Condition 2 (sums arising on or after 6 April 2015 and before 22 October 2015) - A management fee arising to the individual: Fact dependent circumstances

update changes following review

Co-investment: Arm's length returns

update changes following review

Returning sums chargeable under the disguised investment management fees (DIMF) rules:

update changes following review

1 October 2020

Deemed trade: Contents

published immediately in error. Setting back to 'unpublished' to correct.

published immediately in error. Setting back to 'unpublished' to correct.

22 April 2020

Real Estate Investment Trust : Property rental business income: investment/trading borderline: 3-year development rule: interpretations: CTA2010/S556

Guidance on the meaning of Completion updated.

2019

2 October 2019

Investors in authorised investment funds (AIFs) receiving trail commission

Page updated to reflect the Hargreaves Lansdown litigation.

Investors in property authorised investment funds: trail commission

Page updated to reflect the Hargreaves Lansdown litigation.

Investors in tax elected funds (TEFs): tax treatment of distributions: trail commission

Page updated to reflect the Hargreaves Lansdown litigation.

11 September 2019

Real Estate Investment Trust : Residual income: general

trying to get it visible!

28 August 2019

Real Estate Investment Trust : Background: Key Concepts: Property Rental Business

Reference to S205 and S206 corrected to CTA 2009 (previously shown as CTA 2010).

6 August 2019

Real Estate Investment Trust : Joint ventures: Joint Venture Look-Through Notice: effects of notice: CTA2010/S588 and S589

Page republished

5 August 2019

Real Estate Investment Trust : Leaving the regime: exit by HMRC notice: CTA2010/S572

Page republished

Real Estate Investment Trust : Breaches of conditions: Distribution Condition: general: CTA2010/S564

Page republished

25 July 2019

When dividends can be designated as interest distributions

sh title

12 July 2019

Offshore Funds: participants in offshore funds: participants within the charge to corporation tax: introduction: contents

sh title
main title duplicated 13200

9 July 2019

Taxation of investment trusts: Interest distributions: Introduction

Updated titles

8 July 2019

Taxation of authorised investment funds: introduction

short title

Authorised investment funds (AIFs): taxation of funds: investment transactions - anti-avoidance

Republished

6 July 2019

Offshore Funds: investors in non-reporting funds: computation of offshore income gain: previous no gain / no loss disposals

format tables

Co-ownership Authorised Contractual Schemes (CoACS): Calculation of plant and machinery allowances

Update title and content to relate specifically to plant and machinery allowances.

5 July 2019

Introduction to Investment Funds Manual

Back to draft

Taxation of authorised investment funds

Back to draft

IFM04350 AIFs: Property authorised investment funds (PAIFs): tax treatment of PAIFs and distributions: excess financing costs in a qualified investor scheme (QIS)

Draft

Approval of an exempt unauthorised unit trust (EUUT)

Draft

AIFs: Property authorised investment funds (PAIFs): deducting and accounting for tax from distributions: gross payments of property income distributions

Draft

AIFs: Property authorised investment funds (PAIFs): deducting and accounting for tax from distributions: deduction of tax from distributions made by PAIFs

Draft

Property authorised investment funds (PAIFs): introduction and conditions of membership for the regime

Draft

Property authorised investment funds (PAIFs): introduction and conditions of membership for the regime: introduction

Draft

Property authorised investment funds (PAIFs): introduction and conditions of membership for the regime: overview of conditions

Draft

Property authorised investment funds (PAIFs): introduction and conditions of membership for the regime: the property investment business condition

Draft

Property authorised investment funds (PAIFs): introduction and conditions of membership for the regime: foreign equivalents to ‘UK REITs’

Draft

Property authorised investment funds (PAIFs): introduction and conditions of membership for the regime: intermediate holding vehicles

Draft

Property authorised investment funds (PAIFs): introduction and conditions of membership for the regime: the genuine diversity of ownership condition

Draft

Property authorised investment funds (PAIFs): introduction and conditions of membership for the regime: the corporate ownership condition

Draft

Property authorised investment funds (PAIFs): introduction and conditions of membership for the regime: the loan creditor condition

Draft

Property authorised investment funds (PAIFs): introduction and conditions of membership for the regime: the balance of business condition

Draft

13 June 2019

Co-ownership Authorised Contractual Schemes (CoACS): Capital allowances: introduction

Add reference to SBA & clarify that existing material relates to plant and machinery allowances - agreed with I&G.

16 May 2019

Offshore Funds: participants in offshore funds: participants within the charge to income tax: disposals: reporting funds

reformat table

Offshore Funds: participants in offshore funds: participants within the charge to corporation tax: disposals: disposals of reporting funds

reformat table

Offshore Funds: participants in offshore funds: participants within the charge to income tax: disposals: reporting funds: example

format tables

14 May 2019

Investors in tax elected funds (TEFs): investors within the charge to corporation tax (CT): disposals

hgtyt

9 May 2019

Real Estate Investment Trust : Capital gains: general : CTA2010/S535 and S535A

Updated for NRCGT
Trying to update links

n/a

8 May 2019

Real Estate Investment Trust :Prescribed arrangements: 2009/3315 - Real Estate Investment Trusts (Prescribed Arrangements) Regulations 2009

supposed to be publishing

Real Estate Investment Trust : Property rental business income: investment/trading borderline: 3 year development rule: CTA2010/S556

publ

Real Estate Investment Trust : Capital gains: computational rules: Company ceasing to be a member of a group (disposal of shares): CTA2010/S559 and S579

hopefull publ

Real Estate Investment Trust : Capital gains: transactions within groups: examples (2)

minor editing

Real Estate Investment Trust : Capital Gains: Contents

no change

Real Estate Investment Trust : Distributions: attribution rules: category (d) - gains of the property rental business: CTA2010/S550(2)(d)

dfd

Real Estate Investment Trust : Distributions: administration: attribution: example

dds

Real Estate Investment Trust : Conditions and Tests: maximum shareholding: formula to work out notional income: CTA2010/S552

CS can't publish, put back to draft.

Real Estate Investment Trust : Group conditions and rules : Financial statements: basics : CTA2010/S532 - S533

Additional paragraph added at end of page

7 May 2019

Real Estate Investment Trust : Background: General Definitions Relating To Parts of a UK-REIT

spelling mistake corrected in final line - principle changed to principal

Real Estate Investment Trust : Property rental income : Calculation of property rental business profits: general: CTA2010/S599

I haven't changed anything in this one but am being asked to complete this field

Real Estate Investment Trust : Entry to the regime: effects of entry: cessation of business and accounting period: CTA2010/S536

typos amended

Real Estate Investment Trust : Entry to the regime: overview

I haven't changed anything in this one but am being asked to complete this field

Real Estate Investment Trust : Group conditions and rules: Financial Statements: UK property rental business: entities that are not wholly owned

I haven't changed anything in this one but am being asked to complete this field

Real Estate Investment Trust : Group conditions and rules: Financial Statements: UK property rental business

I haven't changed anything in this one but am being asked to complete this field

Real Estate Investment Trust : Group conditions and rules: Financial Statements: financing costs

I haven't changed anything in this one but am being asked to complete this field

Real Estate Investment Trust : Group conditions and rules: Financial Statements: property rental business and residual: other entities – table

I haven't changed anything in this one but am being asked to complete this field

Real Estate Investment Trust : Background : Group REITs: non-resident group members: UK property rental business

update for NRCGT

3 May 2019

Investors within the charge to corporation tax

Resending for review.

26 April 2019

Offshore funds: introduction and contents

updating menu, then resending for review/publication

24 April 2019

Real Estate Investment Trust : Background: Overview Of The Regime

spelling mistake corrected - 3rd line from bottom rntal changed to rental

23 April 2019

Real Estate Investment Trust : Background: Fundamentals: The Ring Fence

publishing