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HMRC internal manual

International Exchange of Information Manual

Investment Entity: Collective Investment Schemes

Collective Investment Schemes

A Collective Investment Scheme is an entity that will, by its nature, fall within the definition of Investment Entity [see IEIM400760]. This will include entities that fall within the meaning of Collective Investment Schemes for the purpose of the Financial Services and Markets Act and will also include any UK resident company that is:

  • an investment trust for the purposes of the Corporation Taxes Acts (see Section 1158 of the Corporation Tax Act 2010),
  • a venture capital trust within the meaning of Part 6 of the Income Tax Act 2007.


Although an Investment Trust Company (ITC) or a Venture Capital Trust (VCT) will be a Reporting UK Financial Institution it will not generally need to report on its shares and securities for the purposes of either the FATCA or CDOT IGAs. Under both FATCA and CDOT, equity and debt interests in an Investment Entity that are regularly traded on an established securities market are not financial accounts.  ITC and VCT shares are invariably listed on the London Stock Exchange. Further details on the meaning of ‘regularly traded on an established securities market’ can be found at [see IEIM403230].

The regularly traded exemption is not available under the CRS and DAC regimes, consequently the equity and debt interests in ITC and VCT, along with any other Collective Investment Scheme that is listed on a recognised securities market, will be financial accounts and reportable if held by a Reportable Person.