STSM082090 - Trusts and pension schemes: pension schemes: Pension Funds Pooling Schemes

A unit trust scheme which is a pension funds pooling scheme (PFPS) is not treated as a unit trust scheme for Stamp Duty or SDRT purposes, owing to the Stamp Duty and Stamp Duty Reserve Tax (Pension Funds Pooling Schemes) Regulations 1996 (SI 1996/1584).

This enables investors both to contribute and withdraw investments from a PFPS without a charge to Stamp Duty or SDRT. That is, the units issued as consideration are not treated as stock for Stamp Duty purposes or as chargeable securities for SDRT.

The regulations governing PFPSs allow them to be treated in the same way as Common Investment Arrangements for stamp taxes purposes. Without these regulations, the schemes would be treated as unit trust schemes, being collective investment schemes under which property is held on trust for the participants.