Collective investment schemes: authorised investment funds
Authorised Investment Funds (AIFs) are chargeable to corporation tax
All Authorised Investment Funds (AIFs), whether they are authorised unit trusts (AUTs) or open-ended investment companies (OEICs) fall into one of three categories defined by theFSA.
* UCITS funds: these are AIFs which are within the European UCITS (undertakings for collective investments in transferable securities) directive, which can be marketed within any European Union member state. * Non-UCITs Retail Funds (often referred to as NURS funds): these are AIFs which, whilst not being UCITS schemes are not Qualified Investor Schemes; their investment powers are less restricted than UCITS schemes. * Qualified Investor Schemes (QIS): these are AIFs with wider investment and borrowing powers than either UCITS funds or NURS funds and can be marketed only to ‘qualified’ investors.
As companies, AIFs are chargeable to corporation tax. See CTM48200 onwards for the corporation tax treatment of collective investment schemes established as authorised unit trusts or open-ended investment companies.
Umbrella schemes / umbrella companies
See CTM48410 (SAIM20000) for an explanation of these and the tax treatment applying, and for cross-references to the capital gains manual for details of the treatment for chargeable gains purposes of exchanges of units between sub-funds.