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HMRC internal manual

Stamp Duty Land Tax Manual

SDLTM31305 - Introduction

Co-Ownership Authorised Schemes (CoACSs) and Reserved Investor Funds (RIFs) are both types of Co-Ownership Contractual Scheme (CoCS). 

FA03/S102 provides that a CoCS is treated as if the scheme is a company, and the rights of the participants are shares in that company. 

An exception to this applies in respect of group relief, reconstruction and acquisition reliefs under FA03/SCH7. See SDLTM23000+. 

Where there is an umbrella scheme, each separate sub-fund or pool is regarded as a separate CoCS, and the umbrella scheme as a whole is not regarded as a CoCS.