Camilla Spielman
Camilla has provided tax advice to the Financial Services Group since 1990. She has wide experience of advising on the taxation of all types of investment funds and in particular advises fund management groups on new product development.
Camilla's UK work includes the tax structuring for authorised unit trust and OEIC launches and reconstructions, for both securities and property funds. She also advises on unauthorised funds, including exempt unauthorised unit trusts. Offshore, she advises on the structuring and restructuring of traditional and alternative funds, both open and closed-ended.
Recently, Camilla has worked on the launch and seeding of the Royal London Asset Management UK property authorised contractual scheme with a PAIF feeder. She has acted as sole or lead tax adviser in relation to most existing authorised contractual schemes and PAIFs, as well as on the only PAIF merger to date.
Camilla has contributed chapters to Tolley's Taxation of Collective Investment, IBFD online publication on Investment Funds and Private Equity as well as articles to journals. She has been involved in many industry initiatives including the development of PAIFs and authorised contractual schemes. She is a member of The Investment Association and Association of Real Estate Funds' tax committees.
Camilla's UK work includes the tax structuring for authorised unit trust and OEIC launches and reconstructions, for both securities and property funds. She also advises on unauthorised funds, including exempt unauthorised unit trusts. Offshore, she advises on the structuring and restructuring of traditional and alternative funds, both open and closed-ended.
Recently, Camilla has worked on the launch and seeding of the Royal London Asset Management UK property authorised contractual scheme with a PAIF feeder. She has acted as sole or lead tax adviser in relation to most existing authorised contractual schemes and PAIFs, as well as on the only PAIF merger to date.
Camilla has contributed chapters to Tolley's Taxation of Collective Investment, IBFD online publication on Investment Funds and Private Equity as well as articles to journals. She has been involved in many industry initiatives including the development of PAIFs and authorised contractual schemes. She is a member of The Investment Association and Association of Real Estate Funds' tax committees.
Practice Area
Panel
- Contributing Author
5 Contributions by Camilla Spielman
PRACTICE NOTES
Corporation tax on UK corporate investors in authorised investment funds (OEICs and AUTs): bond v equity status, distributions, loan relationships, corporate streaming, chargeable gains, umbrella funds, equalisation and anti-avoidance
This Practice Note explores the tax position of investors in open‑ended investment companies (OEICs) and authorised unit trusts (AUTs) who fall within the scope of UK corporation tax—namely UK‑resident companies and non‑UK resident companies trading through a UK permanent establishment. These investors are described here as ‘corporate investors’. Note that bespoke provisions, not addressed in this Practice Note, may apply where the investor is an insurance company or a financial trader. In statute, OEICs and AUTs are jointly defined as authorised investment funds (AIFs). The main provisions that determine how AIFs and their investors are taxed appear in the Authorised Investment Funds (Tax) Regulations 2006 (SI 2006/964) (the AIF Tax Regulations).
For:
what OEICs and AUTs are and an outline of the relevant regulatory framework, see Practice Note: Tax and authorised investment funds—what are they?...
Tax
PRACTICE NOTES
UK authorised investment funds: fund-level corporation tax, gains exemption and distribution rules for OEICs and AUTs, including bond v equity classification, GDO and umbrella sub-funds
FORTHCOMING CHANGE relating to the UK funds regime :
The outcome of the government’s review of the UK funds regime (see News Analyses: Review of the UK funds regime—an analysis and HM Treasury’s review of the UK funds regime—a call for input) includes proposals to keep the tax position of the new long-term asset fund (LTAF) under ongoing scrutiny.
This Practice Note considers the taxation of authorised investment funds (AIFs). In tax terminology, ‘authorised investment fund’, or ‘AIF’, is the umbrella term for two fund types: the authorised unit trust (AUT) and the open-ended investment company (OEIC). Both AUTs and OEICs are forms of collective investment scheme that are authorised and regulated by the Financial Conduct Authority (FCA).
The expression ‘AIF’, used for these funds, appears in the Authorised Investment Funds (Tax) Regulations 2006, SI 2006/964, which contain the principal rules governing their taxation. In this subtopic, those regulations are referred to as the ‘AIF Tax Regulations’. Note that the abbreviation ‘AIF’ in a tax context (ie signifying ‘authorised investment fund’) should not be confused with the same term when used in a regulatory, non-tax context...
Tax
PRACTICE NOTES
UK authorised investment funds: Genuine diversity of ownership: Conditions A-C, scope, application to AIF/PAIF/TEF and 'white list', LTAF deeming, feeder funds, HMRC advance clearance
FORTHCOMING CHANGE relating to the UK funds regime :
The outcome of the government’s review of the UK funds regime (see News Analyses: Review of the UK funds regime—an analysis, and HM Treasury’s review of the UK funds regime—a call for input) contains proposals to keep the tax treatment of the new long-term asset fund structure (LTAF) under ongoing review.
This Practice Note considers the genuine diversity of ownership (GDO) requirement, which:
certain authorised investment funds must meet to obtain favourable tax treatment under the tax regime applicable to authorised investment funds; and
all authorised investment funds must meet to benefit from the certainty provided by the ‘investment transactions list’ (sometimes called the ‘white list’); and
relevant authorised investment funds must meet to enter the property AIF (PAIF) or tax elected fund (TEF) tax regimes
The expression ‘authorised investment fund’ (AIF) is used in tax legislation to refer collectively to two fund types: the authorised unit trust (AUT) and the open-ended investment company (OEIC). AUTs and OEICs are forms of collective investment scheme that are authorised and regulated by the Financial Conduct Authority (FCA)...
Tax
PRACTICE NOTES
UK tax and regulatory overview of authorised investment funds (AUTs and OEICs), including UCITS, NURS, QIS, LTAF, PAIFs, TEFs, unit classes and umbrella funds
FORTHCOMING CHANGE relating to the UK funds regime :
Following the government’s examination of the UK funds regime, proposals include continuing to monitor the tax treatment of the new long‑term asset fund structure (LTAF) (see News Analyses: Review of the UK funds regime—an analysis and HM Treasury’s review of the UK funds regime—a call for input). In tax parlance, ‘authorised investment fund’ (AIF) covers two vehicles: the authorised unit trust (AUT) and the open‑ended investment company (OEIC). Both AUTs and OEICs are forms of collective investment scheme, authorised and regulated by the Financial Conduct Authority. The label ‘AIF’, applying to both, appears in the Authorised Investment Funds (Tax) Regulations 2006, SI 2006/964, which set out the core tax rules for these funds. Within this subtopic, those provisions are called the ‘AIF Tax Regulations’. AUTs and OEICs sit within the wider category of collective investment schemes and must be authorised and regulated by the Financial Conduct Authority to operate. Be aware that ‘AIF’ in a tax sense (ie meaning ‘authorised investment fund’) is distinct from the same acronym in a regulatory, non‑tax setting, and the two uses should not be confused...
Tax
PRACTICE NOTES
UK taxation of individual investors in authorised investment funds (OEICs and AUTs): interest/dividend distributions, bond versus equity classification, CGT on disposals, accumulation units, equalisation and umbrella funds
FORTHCOMING CHANGE relating to abolition of the non-dom regime and introduction of a residence-based regime:
In the Autumn Budget 2024, the government signalled it will advance the previous administration’s proposal to scrap the remittance basis of taxation for non‑UK domiciled individuals and bring in a residence‑based regime, taking effect from 6 April 2025.
For details on these changes, see Practice Note: The abolition of the remittance basis of taxation from 2025–26 and News Analyses: Autumn Budget 2024—Private Client analysis—International and Autumn Budget 2024—reforming the taxation of non-doms.
This Practice Note considers how UK income tax applies to investors in open‑ended investment companies (OEICs) and authorised unit trusts (AUTs). Throughout, these investors are termed ‘individual investors’.
Be aware that distinct provisions, not covered here, can apply to investors acting as financial traders. Non‑UK residents might be taxed on income and gains in their own jurisdiction of residence under local law. Tax legislation collectively labels OEICs and AUTs as authorised investment funds (AIFs)...
Tax
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