VATFIN5500 - Management of investments and portfolios, funds and ‘wrapper’ products and related services: Wrappers, Wraps, Nominee Accounts and Fund Supermarkets

Tax Efficient Wrapper products

"Wrapper" products hold investments in a tax efficient wrapper making them free of income and capital gains tax, and are aimed at trying to stimulate the general public into saving and investing money. Examples of these products (current and historical) include Individual Savings Accounts (ISAs), Child Trust Funds (CTFs), Personal Equity Plans (PEPs) and Self- Invested Person Pensions (SIPPs). See VATFIN5700 for more information on these products.


Wrap Accounts

A wrap account is an arrangement that holds a range of investments, providing a single point of contact and management for investors and their agents.

A wrap manager is usually a separate legal entity within a financial services or insurance group that offers to hold, manage and administer the whole or part of an individual’s portfolio. The wrap account itself might typically be an interest-bearing bank account, with a set of sub- accounts, allowing payments to be made and received within broad product silos, allowing the VAT treatment of the service to be analysed.

The wrap manager nominates a third-party discretionary investment manager and an execution-only broker. The discretionary investment manager generally offers, or is required by the wrap manager to offer, nominee account services. It may also offer custody services, or these may be provided by another entity.

The typical charging structures for wrap products are based on transaction charges, calculated by reference to the value of investments within the wrap account (taken as a strong indicator of activity going through the account), including dividends, interest, and principal amounts. The VAT liability of a Wrap depends on the nature of the supplies made and in case of doubt please contact HMRC.


Nominee accounts

The simplest form of a wrap account is a “nominee account”. Investors will typically make investments through a bank or building society account or via an Independent Financial Advisor (“IFA”), stockbroker or other type of intermediary. Many of these operate nominee account arrangements. As far as the provider (e.g. the fund manager) is concerned, it receives a purchase instruction registered in the name of a nominee account. The fund manager does not need to have, and usually does not have, a relationship with the underlying investor. The intermediary will receive ongoing reporting / disclosures from the provider, which it will forward (appropriately customised / apportioned) to the underlying investors, of which there may be hundreds, or even thousands.


Fund supermarkets

Funds supermarkets provide a particular form of wrap account. They provide access to a variety of collective funds managed by different fund managers. They are like supermarkets in that an investor is the shopper, the products are the funds, and the supermarket is the shop. They may offer advice or analytical decision/fund selection tools or simply provide “execution only” services.

Fund supermarkets allow investors to purchase fund shares / units from a variety of fund managers, usually at discounted prices. Such shares / units may be wrapped within a PEP or ISA, or held as stand alone investments. The investor has a contractual relationship with the supermarket, and does not deal direct with the fund manager. Likewise, fund managers have no knowledge of individual investors – they simply see net, bulk orders from the supermarket’s nominee account to sell or buy shares/units.

Typical services undertaken by the supermarket may include:


  • fund transaction clearance and settlement;
  • receipt and payment of fund distributions;
  • maintenance of investors’ fund information (share/unit balances, dividend and distribution information and transaction history);
  • issue of all confirmations, statements, prospectuses and literature to investors;
  • sending of any tax vouchers to investors, including the amount of dividend and interest paid; and
  • holding (by the supermarket, or its nominee/custodian), of the shares/units subscribed for by investors, together with any reinvested dividends and distributions.

Investors usually pay no fee to the supermarket itself. Instead, the supermarket usually receives commission from the fund manager, which may be taken in the form of a rebate of the management fee. In this case, the “commission” represents a bulk discount for a large nominal investor, and, as such, is not a taxable supply.