SAIM6020 - Collective investment
schemes: authorised investment funds
Authorised Investment Funds (AIFs) are chargeable to
corporation tax
All Authorised Investment Funds (AIFs), whether they are
authorised unit trusts (AUTs) or open-ended investment companies
(OEICs) fall into one of three categories defined by the FSA.
- UCITS funds: these are AIFs which are
within the European UCITS (undertakings for collective investments
in transferable securities) directive, which can be marketed within
any European Union member state.
- Non-UCITs Retail Funds (often referred to
as NURS funds): these are AIFs which, whilst not being UCITS
schemes are not Qualified Investor Schemes; their investment powers
are less restricted than UCITS schemes.
- Qualified Investor Schemes (QIS): these
are AIFs with wider investment and borrowing powers than either
UCITS funds or NURS funds and can be marketed only to
‘qualified’ investors.
As companies, AIFs are chargeable to corporation tax. See
CTM48200 onwards for the corporation tax treatment of collective
investment schemes established as authorised unit trusts or
open-ended investment companies.
Umbrella schemes / umbrella companies
See
CTM48410 (
SAIM20000) for an explanation of these
and the tax treatment applying, and for cross-references to the
capital gains manual for details of the treatment for chargeable
gains purposes of exchanges of units between sub-funds.
