Camilla Spielman

This Practice Note explains the tax treatment of entities within the charge to UK corporation tax who invest in open-ended investment companies (OEICs) and authorised unit trusts (AUTs). Such funds are together referred to for tax purposes as authorised investment funds (AIFs). This Practice Note looks at the tax treatment of fund distributions and of disposals of investments where the particular AIF is a so-called bond fund or equity fund. It also looks at the corporate streaming rules, qualifying investments test, equalisation and anti-avoidance rules. This Practice Note is produced in partnership with Camilla Spielman of Eversheds Sutherland.

This Practice Note describes the genuine diversity of ownership (GDO) condition which authorised investment funds (AIFs) are required to satisfy in certain situations. First, AIFs which are qualified investor schemes (QIS) or long-term asset funds (LTAFs) for regulatory purposes must satisfy the GDO condition in order to access the AIF tax regime. Second, all AIFs must satisfy the GDO condition in order to benefit from the ‘investment transactions list’ (sometimes referred to as the ‘white list’) which can provide certainty that capital profits will not be recharacterised as trading profits taxable as income. Third, the GDO condition allow relevant AIFs to enter into the property AIF (PAIF) and tax elected fund (TEF) tax regimes. This Practice Note also looks at the GDO advance clearance procedure. This Practice Note is produced in partnership with Camilla Spielman of Eversheds Sutherland.

This Practice Note explains the tax treatment of UK resident individuals who invest in open-ended investment companies (OEICs) or authorised unit trusts (AUTs). Such funds are together referred to for tax purposes as authorised investment funds (AIFs). This Practice Note looks at the tax treatment of fund distributions where the particular AIF is a so-called bond funds or equity fund, and at the CGT rules applicable to disposals, equalisation and umbrella funds. This Practice Note is produced in partnership with Camilla Spielman of Eversheds Sutherland.

This Practice Note looks at the taxation of authorised unit trusts (AUTs) and open-ended investment companies (OEICs), which are collectively referred to as authorised investment funds (AIFs) for tax purposes and are subject to a specific taxing regime. As part of this, it covers the investment transactions list, which the UK tax rules applicable to other types of fund also utilise. This Practice Note is produced in partnership with Camilla Spielman of Eversheds Sutherland.

This Practice Note explains the two legal forms of ‘authorised investment fund’ (AIF) that are recognised for UK tax purposes—the authorised unit trust (AUT) and the open-ended investment company (OEIC). These are both varieties of collective investment scheme that are authorised and regulated by the Financial Conduct Authority and this Practice Note also looks at the different regulatory forms that an AIF can take. This Practice Note also describes how AIFs can be set up as umbrella funds. This Practice Note is produced in partnership with Camilla Spielman of Eversheds Sutherland.