SDLTM09945 - SDLT - increased rates for non-resident transactions: Co-ownership authorised contractual schemes - para 15 Sch 9A FA03

General guidance on co-ownership authorised contractual schemes (CoACSs) can be found at IFM08000 onwards.

A CoACS is a form of collective investment scheme. It is essentially a pool of assets held by a depositary and managed on behalf of a number of investors in accordance with contractual arrangements agreed between the parties. For SDLT purposes, a CoACS is treated as a company, and the rights of investors are shares in the company.

With one exception, a CoACS is UK resident for the purposes of the surcharge (paragraph 15(1)).

The exception to this rule is that certain collective investment schemes which are treated as CoACSs under section 102A of FA 2003 (EEA equivalent schemes) are non-resident for the purposes of the surcharge (paragraph 15(2)).