Authorised investment funds (AIFs)—taxation of corporate investors
Produced in partnership with Camilla Spielman of Eversheds Sutherland
Authorised investment funds (AIFs)—taxation of corporate investors

The following Tax guidance note Produced in partnership with Camilla Spielman of Eversheds Sutherland provides comprehensive and up to date legal information covering:

  • Authorised investment funds (AIFs)—taxation of corporate investors
  • Taxing investments in AIFs—basic principles
  • Bond funds v equity funds
  • Holdings in bond funds
  • Holdings in equity funds—distributions
  • Taxation of dividend distributions—corporate streaming rules
  • Holdings in equity funds—disposals
  • Umbrella funds
  • Equalisation
  • Anti-avoidance provisions relating to financial traders

This Practice Note examines the taxation of investors in open-ended investment companies (OEICs) and authorised unit trusts (AUTs) that are within the charge to UK corporation tax—ie UK resident companies and non-UK resident companies carrying on a trade through a UK permanent establishment.

Such investors are referred to in this Practice Note as ‘corporate investors’. Note that special rules, not explored in this Practice Note, may apply to insurance companies and financial traders.

OEICs and AUTs are together referred to as authorised investment funds (AIFs) for tax purposes. Most of the key provisions relating to the taxation of AIFs and their investors are contained in the Authorised Investment Funds (Tax) Regulations 2006, SI 2006/964 (the AIF (Tax) Regs).

For:

  1. more on OEICs and AUTs and for an overview of the relevant regulatory framework, see Practice Note: Authorised investment funds (AIFs)—what are they?

  2. the tax treatment of the AIF fund vehicle itself, see Practice Note: Authorised investment funds (AIFs)—taxation of the fund, and

  3. the taxation of individual investors in AIFs, see Practice Note: Authorised investment funds (AIFs)—taxation of individual investors

Taxing investments in AIFs—basic principles

This Practice Note examines how corporate investors in AIFs are taxed in respect of the returns arising on their investments in such funds—ie fund distributions and the proceeds on a disposal of an investment. The UK tax