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HMRC internal manual

Company Taxation Manual

Authorised investment funds (AIFs): structure, arrangement and tax status of funds: distribution accounts, period and date

Distribution

This is treated as being the total amount shown in the accounts as available for distribution to participants. It includes amounts credited to the capital part of the scheme property of an authorised investment fund (AIF) on behalf of a participant in respect of the participant’s accumulation units (SI2006/964 Regulations 15, 18(2) and 22(2)).

Distribution accounts

These are defined for tax purposes as accounts showing the total amount available for distribution to participants and how that total amount is calculated (SI2006/964 Regulation 15(3)).

Distribution period

This is a period by which the total amount available for distribution to participants is calculated (SI2006/964 Regulation 15(2)).

Under Financial Conduct Authority (FCA) rules in its ‘COLL’ handbook the period cannot last more than a year and may be shorter. It is normally six months.

Accounts must, in any event, be prepared half yearly.

Distribution date

This is the date specified in the instrument of incorporation of the open-ended investment company or the terms of the authorised unit trust or, if no date is specified it is the last day of the distribution period (SI2006/964 Regulation 15(4)).

Under FCA rules (COLL) any date specified as a distribution date must always be within four months of the end of the corresponding distribution period.