BVCA 1987 Statement meaning

bvca 1987 statement describes the BVCA’s statement and guidelines dated 26 May 1987, approved by HMRC, on structuring and operating UK limited partnerships as venture capital and private equity investment funds. It is industry guidance (not legislation or case law) that practitioners use in UK fund formation and tax analysis. At a high level, it evidences HMRC’s acceptance of the limited partnership as a suitable, tax‑transparent vehicle when run as an investment (not trading) fund, and it informs market practice on the roles of the general partner, fund manager and limited partners. Section 2, which addressed the taxation of individual partners involved in management and carried interest, has been superseded by the HMRC-BVCA Memorandum of Understanding on Carried Interest (the Carry MoU). Other parts continue to be cited, subject to later statutory changes. Across England & Wales, Scotland and Northern Ireland it is routinely applied; it has no direct application in Ireland, where separate Revenue guidance applies. In practice, the Statement is frequently referenced in private placement memoranda, limited partnership agreements and tax opinions to support non‑trading status and investor tax transparency for UK limited partnership funds.