The reserved investor fund regime: restricted or unrestricted, that is the question

The government is consulting on the introduction of a reserved investor fund (RIF) regime which would take the form of a contractual scheme that may be marketed to professional investors and certain other sophisticated investors only. Views are sought on a range of issues concerning the design of the proposed new fund in particular the design of the tax regime for such a fund. Industry feedback suggests that such a fund may be used mostly for real estate investment although separately there has been significant interest generally in the creation of a broader tax exemption regime for onshore UK fund vehicles. Due to concerns around the interaction between the RIF and the non-resident capital gains rules the RIF regime may need to be restricted to certain scenarios that do not give rise to exchequer risks. As an alternative the consultation does consider the case for...