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HMRC internal manual

Company Taxation Manual

Tax elected funds (TEFs) : breaches of conditions : introduction


Chapter 2, SI2006/964 sets out the conditions that must be met in order for an authorised investment fund (AIF) to adopt the TEF regime. The conditions themselves are explained earlier in this guidance (CTM48912 to CTM48916). The pages at CTM48962 to CTM48964 explains how breaches of those conditions are treated. CTM48962 explains general breaching rules that apply if any of the conditions are breached and then CTM48963 to CTM48964 set out more specific rules for each condition that is breached.

Multiple breaches of separate conditions

In addition to any consequences of single or multiple breaches of specific conditions, there are also consequences when the TEF breaches more than one separate condition - see CTM48965.

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Information notice

CTM48966 sets out the information requirements that the manager of a fund will need to comply with where HMRC believe that a fund has or may have breached a condition.