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PRACTICE NOTES
The tax regime for property authorised investment funds (PAIFs) applies to UK open-ended investment companies (OEICs) which satisfy a number of conditions. In certain circumstances, a failure to meet these conditions can lead to expulsion from the PAIF regime. PAIFs can, of course, also elect to leave the regime of their own volition. The precise effect of breaching the PAIF conditions depends on the particular condition breached and, in some cases, whether it has been breached before. The PAIF conditions are covered in detail in Practice Note: PAIFs—the conditions. This Practice Note looks at: • what happens when one or more conditions of the PAIF regime are breached, and • the tax effects of an exit from the PAIF regime For a summary overview of the PAIF regime as a whole, see Practice Note: Tax and property funds—overview. For the tax treatment of PAIFs and their investors, as well as certain related compliance obligations, see Practice Note: PAIFs—tax treatment of the fund and its investors. The tax rules for PAIFs are
PRACTICE NOTES
FORTHCOMING CHANGE relating to income tax rates applicable to dividends: As announced at Budget 2025, Finance Bill 2026 contains provisions which will increase the income tax rates applicable to dividend income from 6 April 2026. The dividend ordinary rate (applicable to dividend income that would otherwise be charged at the basic rate) and the dividend upper rate (applicable to dividend income that would otherwise be charged at the higher rate) will be increased by two percentage points to 10.75% and 35.75%, respectively. The dividend additional rate (applicable to dividend income that would otherwise be charged at the additional rate) will remain unchanged at 39.35%. The UK tax regime for property authorised investment funds (PAIFs) is designed to create an open-ended collective investment vehicle for property, which allows investors: • to be taxed in the same (or nearly the same) way as if they invested in the property directly, and • to benefit from: ◦ the professional management of the property held by the fund, and ◦ the
PRACTICE NOTES
The tax regime applicable to property authorised investment funds (PAIFs) applies to UK open-ended investment companies (OEICs) which: • satisfy a number of conditions, and • have notifed HMRC in advance that they wish the PAIF regime to apply to them This Practice Note focuses on the conditions which must be met for the PAIF regime to apply to an OEIC. For a high-level summary of the PAIF tax regime as a whole, see Practice Note: Taxation of property funds—overview. Other aspects of the regime are examined in Practice Notes: PAIFs—tax treatment of the fund and its investors and PAIFs—breaches and exit. Note that there is a good deal of overlap between the PAIF tax regime and the UK tax rules for real estate investment trusts (REITs). Given the intended complementary nature of the two regimes (the PAIF regime being designed for open-ended vehicles investing in real estate, and the REIT regime for closed-ended vehicles established with a similar purpose) this is unsurprising. For a summary overview of the REIT regime, see Practice
PAL
GLOSSARY
See Provisional allotment letter.
GLOSSARY
An accurate and quick method for leak testing on a variety of containment systems such as gloveboxes and hot cells.
PAS
GLOSSARY
Public Address System ("Tannoy")
NEWS
The Planning Advisory Service (PAS) has introduced a comprehensive self-assessment toolkit for local planning authorities aimed at optimising the performance of their planning committees. Drawing on findings from the Modernising Planning Committees National Survey conducted between October–December 2024, the toolkit covers 14 operational areas. The toolkit outlines best practice protocols and emphasises transparency and due process in decision-making, thereby reducing legal risks, enhancing decision quality, and supporting consistent, defensible outcomes. Notably, it addresses upcoming government reforms such as a proposed 11-member committee size limit and a potential national delegation scheme, providing councils with a comprehensive framework to assess and align their practices with emerging regulatory requirements.
NEWS
The Pensions Administration Standards Association (PASA) has published its response to the Pensions Regulator (TPR)'s September 2025 enforcement strategy consultation. In its response, PASA welcomes TPR's focus on saver outcomes, proportionality and early intervention but calls for a clearer distinction between matters handled through guidance and those subject to enforcement. However, it recommends that TPR's enforcement priorities explicitly reference administration quality and data integrity and encourages alignment with existing frameworks, such as PASA's accreditation and standards programmes. PASA also suggests that success metrics should extend beyond the number of enforcement actions to reflect real improvements in saver experience, such as fewer complaints, faster transfer times and stronger data quality.
NEWS
The Pensions Administration Standards Association (PASA) has published new guidance on identity management and assurance for pension schemes. The guidance addresses identity verification across the pension lifecycle. It outlines practices for identity proofing, verification and authentication, including multi-factor and biometric solutions. The guidance aims to help administrators strengthen identity management processes amid increasing digitalisation and evolving fraud risks. Topics covered include high-risk interactions, practical mitigation frameworks and authentication methods tailored to individual scheme circumstances.
NEWS
The Pensions Administration Standards Association (PASA) has published new Guidance on the Ongoing Monitoring of Compliance with Pensions Dashboards Requirements and a new Dashboards Toolkit note on Survivor Benefits to support trustees, scheme managers, pension providers, administrators and connection providers as pensions dashboards move into ongoing operation. Produced by PASA’s Dashboards Working Group, the Guidance focuses on compliance monitoring across matching, pension information provision and connection performance and considers the role of saver queries, complaints and feedback in identifying potential compliance issues and supporting continuous improvement. It also outlines compliance indicators, governance reporting and breach reporting considerations intended to help duty holders monitor ongoing dashboards obligations.
NEWS
The Pensions Administration Standards Association (PASA) has released new guidance on Data Scoring for pension schemes, emphasising the importance of regular, tailored data testing. The guidance recommends annual comprehensive testing of member data, with a focus on scheme-specific requirements. It aims to promote relevant and targeted data testing, build consistency across the industry for better data comparison, and encourage trustees to evidence data quality improvements. PASA has advised against delaying data testing, even during ongoing rectification projects. The Pensions Regulator (TPR) has welcomed the guidance, urging scheme administrators and trustees to review their existing scoring approaches to ensure they meet minimum requirements and adopt good practices highlighted in the document.
NEWS
The Pensions Administration Standards Association (PASA) has published new guidance, ‘Securing Tomorrow: Essential Steps for Trustees and Pension Providers to Protect Member Data’, designed to reinforce data security and governance within pensions administration. The guidance covers areas such as cyber resilience, third-party oversight, secure communications, and responsible AI usage, offering practical recommendations for trustees and providers to counteract rising digital risks, including the implementation of role-based access controls and multi-factor authentication. The new guidance advocates for regular security reviews, the formulation of incident response plans, and proactive preparation for risks associated with emerging technologies such as AI. It aims to provide a vital toolkit for strengthening data management at a time of growing digital risk. The guidance is aligned with the Pensions Regulator's cyber security guidance and the National Cyber Security Centre's10 Steps to Cyber Security; all aimed at strengthening cyber resilience and data security practices across the pensions sector.