SDLTM31315 - Reserved Investor Funds (RIFs)
A Reserved Investor Fund (RIF) is a type of Co-ownership Contractual Scheme (CoCS) which is open to professional and institutional investors, providing more flexibility than existing UK alternatives where the scheme has elected into the RIF tax regime.
Like a CoACS, the scheme is contractual, with investors in a RIF having interests in scheme property as tenants-in-common, with the interest being held by the depository on their behalf.
For the purposes of SDLT, a RIF is treated as a company, with the rights of investors as shares in the company. This means that SDLT is not charged on the buying of units in the RIF, but (without a claim to seeding relief), SDLT is charged when an investor transfers property into the RIF in exchange for units or where the RIF acquires property from a third party.
A RIF is not however treated as a company for the purposes of group, reconstruction or acquisition reliefs.
More information about RIFs can be found in the Investment Funds Manual at IFM08000