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RIFs regulations introduced

The Co-ownership Contractual Schemes (Tax) Regulations SI 2025/200 provide the tax rules for the Reserved Investor Fund (RIF) a new type of investment fund and make associated changes for co-ownership authorised contractual schemes (CoACS). The regulations:

  • set out the tax rules for investors in the RIF: a RIF is not itself a taxable person but it is subject to qualifying criteria conditions and obligations to provide notices and information to its investors and to HMRC;
  • provide minor changes to the tax rules for life insurance companies investing in CoACS a similar type of investment fund. The changes aim to provide consistency on the interaction between parts of the capital allowances and capital gains rules that are relevant for life insurance companies investing in RIFs and CoACS.

The regulations come into force on 19 March 2025 and HMRC have published a Tax Information...

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