An investor who wishes to invest in undertakings for collective investment in transferable securities (UCITS) regulated fund – which offers high levels of investor protection and fund manager marketability – has three options: authorised unit trusts; variable capital investment companies; or contractual funds such as the Luxembourg fonds commun de placement (FCP). Ironically it is only the latter being the one UCITS compliant vehicle not currently offered by the UK which provides a complete UK tax solution.
In May 2011 the UK Treasury announced its intension to compete on a level playing field with other European Member States through the introduction of the tax transparent fund (TTF). The TTF could take the form of a...
