Paul Shaw (Gowling WLG) provides a practical guide to the new regime.
It has for some time been possible to create an Unauthorised Contractual Scheme (UCS) under UK law. A UCS is not an entity in itself but a contractual arrangement between Investors (who agree to pool resources) and an Operator who agrees to invest those pooled resources in accordance with certain agreed parameters. When an Operator makes investments the Investors retain beneficial ownership of any assets acquired with legal title typically held by a nominee or Depositary. HMRC considers a UCS to be transparent or disregarded for UK tax purposes.
FCA-authorised contractual schemes known as ‘Co-ownership Authorised Contractual Schemes’ (CoACSs) have benefited from a special tax regime since 2013. The Co-Ownership Contractual Schemes (Tax) Regulations SI 2025/200 (‘the regulations’) create a parallel tax regime for ‘Reserved Investor Funds’ (RIFs) being contractual schemes that are not...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Paul Shaw (Gowling WLG) provides a practical guide to the new regime.
It has for some time been possible to create an Unauthorised Contractual Scheme (UCS) under UK law. A UCS is not an entity in itself but a contractual arrangement between Investors (who agree to pool resources) and an Operator who agrees to invest those pooled resources in accordance with certain agreed parameters. When an Operator makes investments the Investors retain beneficial ownership of any assets acquired with legal title typically held by a nominee or Depositary. HMRC considers a UCS to be transparent or disregarded for UK tax purposes.
FCA-authorised contractual schemes known as ‘Co-ownership Authorised Contractual Schemes’ (CoACSs) have benefited from a special tax regime since 2013. The Co-Ownership Contractual Schemes (Tax) Regulations SI 2025/200 (‘the regulations’) create a parallel tax regime for ‘Reserved Investor Funds’ (RIFs) being contractual schemes that are not...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
