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HMRC internal manual

Stamp Duty Land Tax Manual

SDLTM31200 - Property authorised investment funds (PAIFs)

A PAIF is an open-ended investment company (OEIC) whose investment portfolio comprisespredominantly of real property or shares in UK Real Estate Investment Trusts (UK REITs) and certain other similar entities, and where taxation on the profits of its property investment business lies with its investors.   

Key requirements 

For a property fund to be within the PAIF regime, it must:  

  • be an OEIC;  

  • have given notice to HMRC to come within the PAIF regime; and  

  • meet certain conditions relating to its ownership and business.   

References to a PAIF are treated as including collective investment schemes incorporated in an EEA state and authorised in a way so that it is equivalent to a UK incorporated PAIF.  

More information about PAIFs can be found in the Investment Funds Manual at IFM04000 

Guidance on Seeding Relief for PAIFs can be found at SDLTM24700