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HMRC internal manual

Company Taxation Manual

Authorised investment funds (AIFs): taxation of funds: capital allowances

It is the authorised investment fund (the open-ended investment company or the trustees of the authorised unit trust) that is entitled to claim any capital allowances and is liable to tax on any balancing charges.

This is because the fund either is a company or, in the case of an authorised unit trust, is treated as a company for tax purposes by ICTA88/S468 (1). The treatment prescribed at section 468(1) explicitly includes the provisions in the Taxes Acts relating to relief for capital expenditure.