Tax analysis: As announced at Autumn Budget 2021, the government has published a number of new consultations and updates on existing consultations, together with announcements on reforms to take forward the government’s plans to progress tax simplification, tackle non-compliance and make sure the tax system is fit for the modern world.

means any taxing, fiscal or other authority (wherever situated) competent to impose, collect or enforce any liability to Tax, including Her Majesty's Revenue & Customs;

This Practice Note provides a brief introduction to Tax Information Exchange Agreements (TIEAs). For a general introduction to the subject of tax information exchange between different jurisdictions, see Practice Note: Exchange of information on tax matters. For guidance on the OECD's Multilateral Convention on Mutual Administrative Assistance in Tax Matters (the Multilateral Convention), see Practice Note: The OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAATM). For an introduction to the automatic exchange of information, including The Foreign Account Tax Compliance Act (known as FATCA) and the Common Reporting Standard (the CRS), see: Offshore tax evasion—overview and Practice Note: Automatic exchange of information—outline. What is a TIEA? A TIEA is a bilateral agreement by which jurisdictions agree to co-operate in tax matters through the exchange of information. Most TIEAs are based on the OECD's Model Agreement on Exchange of Information on Tax Matters (the model Agreement) which was published in 2002. Under the model Agreement, exchange of information is by request only (as opposed to automatic or spontaneous information exchange) and each TIEA sets out

Tax Brexit Q&As Will the VAT Directive still be relevant for UK taxpayers once the Brexit implementation period is over? In the context of Brexit, what is meant by the

“Tax advantage” includes— (a) relief or increased relief from tax, (b) repayment or increased repayment of tax, (c) avoidance or reduction of a charge to tax or an assessment to tax, (d) avoidance of a possible assessment to tax, (e) deferral of a payment of tax or advancement of a repayment of tax, and (f) avoidance of an obligation to deduct or account for tax.

FORTHCOMING CHANGE: A consultation (which closed on 7 July 2025) sought views on options for simplifying, modernising and reforming HMRC’s approach to dispute resolution with the aim of raising awareness of the dispute resolution processes and improving access to (and take-up of) alternative dispute resolution (ADR) and statutory review processes. The consultation also proposes aligning and simplifying the approach for appeals processes to combine the benefits of the different approaches currently used for direct and indirect tax disputes. For more information, see News Analysis articles: Tax update spring 2025—Tax analysis—Taxes management and dispute resolution and Tax update spring 2025—Improving HMRC’s approach to dispute resolution. This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or the judiciary. This Practice Note explains the HMRC tax alternative dispute resolution (ADR) procedure. For more information on ADR generally, see Practice Note: What is ADR? This Practice Note does not cover mediation or ADR in respect of appeals or reviews relating

This Practice Note examines the tax treatment of entities within the charge to UK corporation tax who invest in open-ended investment companies (OEICs) or authorised unit trusts (AUTs). 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 investors who are insurance companies or financial traders. OEICs and AUTs are together referred to in the tax legislation as ‘authorised investment funds’ (AIFs). 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 Regulations). For more on: • what OEICs and AUTs are, and for an overview of the relevant regulatory framework, see Practice Note: Tax and authorised investment funds—what are they? • the tax treatment of the AIF fund vehicle itself, see Practice Note: Tax and authorised investment funds—tax treatment of the fund entity, and • the tax treatment of investors in AIFs who are individuals, see Practice Note:

This Practice Note looks at the genuine diversity of ownership (GDO) condition which AUTs and OEICs are required to satisfy in certain situations in order to benefit from the tax regime for authorised investment funds (AIFs). The relevance of the GDO condition is as follows: • certain AIFs (those who are QIS or LTAFs for regulatory purposes) must satisfy the GDO condition in order to access any part of the AIF tax regime • all AIFs must satisfy the GDO condition in order to benefit from the certainty provided by the ‘investment transactions list’ (sometimes referred to as the ‘white list’) • the GDO condition must be met by any AIFs seeking to enter the property AIF (PAIF) or tax elected fund (TEF) tax regimes As further explained in Practice Note: Tax and authorised investment funds—what are they?, the term ‘authorised investment fund’ (AIF) is used in the tax legislation to collectively refer to two types of fund: the authorised unit trust (AUT) and the open-ended investment company (OEIC).

This Practice Note explains the tax treatment of persons within the charge to UK income tax who invest in open-ended investment companies (OEICs) or authorised unit trusts (AUTs). Such investors are referred to in this Practice Note as ‘individual investors’. Note that special rules, not explored in this Practice Note, may apply to investors who are financial traders. Non-UK residents may be subject to tax on income and gains in their own jurisdiction of residence in accordance with local law. This Practice Note does not specifically consider the position of any individuals who may previously have benefitted from the remittance basis of taxation for non-UK domiciled individuals (that was abolished from 6 April 2025) and/or those who are currently eligible to utilise the four-year foreign income and gains (FIG) regime. For more on this area of individual taxation, see Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and Foreign income and gains regime from 6 April 2025. OEICs and AUTs are together referred to in the tax legislation

This Practice Note looks at the tax treatment of ‘authorised investment funds’ (AIFs). Authorised investment funds/AIFs is the collective tax term that encompasses two types of UK authorised fund: the authorised unit trust (AUT) and the open-ended investment company (OEIC). AUTs and OEICs are varieties of collective investment scheme that are authorised and regulated by the Financial Conduct Authority (FCA). The term ‘authorised investment fund’ (or ‘AIF’) is found in the Authorised Investment Funds (Tax) Regulations 2006, SI 2006/964 (the AIF Tax Regulations) which contain the main body of rules governing the taxation of these types of funds. It is important to note that the abbreviation ‘AIF’ used in this tax context (ie to reference AUTs and OEICs and their tax treatment) should not be confused with that same AIF abbreviation that is used in a regulatory (non-tax) context. In the regulatory (non-tax) context, ‘AIF’ stands for the different concept of the ‘alternative investment fund’ (ie a fund within the UK alternative investment fund managers (AIFM) regime). For more on what AUTs and

An ‘authorised investment fund’ (often abbreviated to ‘AIF’) is tax terminology for two types of authorised fund: the authorised unit trust (AUT) and the open-ended investment company (OEIC). AUTs and OEICs are both varieties of collective investment scheme that are authorised and regulated by the Financial Conduct Authority (FCA). The main body of rules governing the tax treatment of AUTs and OEICs—the Authorised Investment Funds (Tax) Regulations 2006, SI 2006/964 (the AIF Tax Regulations)—uses the term ‘AIF’ for them both, and as a result that terminology is employed in this subtopic. However, it is important to note that this same abbreviation, AIF, is also used in a regulatory (non-tax) context to stand for the different concept of ‘alternative investment fund’ (ie a fund within the UK alternative investment fund managers (AIFM) regime). Regulatory framework What are collective investment schemes? A ‘collective investment scheme’ (CIS) is defined in the Financial Services and Markets Act 2000 (FSMA 2000) as: ‘any arrangements with respect to property of any description, including money, the purpose or effect of which is to enable persons

This Practice Note looks at the following issues in the context of private equity-backed buyouts: • the circumstances in which costs incurred by the acquisition group in connection with the buyout can be relieved against corporation tax • the extent to which any VAT on those costs may be recoverable for the acquisition group It is assumed that all companies making up the acquisition group are UK tax resident and that the buyout is structured as an acquisition of shares in the target company (target). For some more information on how private equity-backed buyouts are typically structured and financed, and other tax issues arising for the acquisition group, see Practice Notes: Tax and management buyouts—what is a management buyout?, Tax and secondary buyouts—what are secondary buyouts? and Tax and buyouts—tax issues for the acquisition group. Structure of a typical buyout A simplified post-buyout structure is illustrated below: Deductibility of deal costs Companies making up the acquisition group will incur a number of transaction costs in the process of a buyout.