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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Authorised investment funds (AIFs): taxation of funds: management expenses

As a company with investment business (ICTA88/S130), an Authorised Investment Fund (AIF) may claim management expenses relief under ICTA88/S75.

Sums appropriated in accordance with the terms of the current prospectus of the AIF for payments to the authorised corporate director and depositary (of an OEIC) or the fund manager and trustee (of an AUT), that are paid by the AIF in respect of the management of the fund’s scheme property are treated as an expense of management for the purposes of section 75.

In the event that an AIF derives some of its income from trading as well as from investments, it will be entitled to a deduction for the expenses of management, including the fund manager’s remuneration, but only to the extent that they are not otherwise deductible, for example in a Case I computation.