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Exempt unit trust meaning

What does Exempt unit trust mean?
An exempt unit trust is a unit trust used to pool assets of tax‑exempt investors—typically pension schemes and charities—so that returns are achieved without trust‑level tax, broadly mirroring direct investment by those investors. In the UK (England & Wales, Scotland and Northern Ireland), the term is descriptive market usage rather than a single statutory definition. It most commonly refers to an exempt unauthorised unit trust (EUUT). Investor eligibility is restricted to entities that are exempt from UK tax; admitting a non‑exempt investor can jeopardise the exemption. Under HMRC rules, income and gains are generally not taxed in the trust and are attributed to investors according to their own tax status. EUUTs are widely used to pool UK real estate and other private market assets to minimise tax leakage and provide administrative efficiency. In Ireland, an Exempt Unit Trust is a specific Revenue‑approved, Central Bank‑regulated unit trust established for exempt pension schemes (and, in some cases, certain other exempt investors). It benefits from trust‑level exemption so that income and capital gains accrue gross, with taxation determined at investor level. Across the UK and Ireland, transaction taxes (SDLT/LBTT/LTT and Irish stamp duty) and VAT may still apply to underlying acquisitions and disposals.
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View the related Practice Notes about Exempt unit trust

PRACTICE NOTES
UK direct tax treatment of Jersey property unit trusts: income transparency, interest and allowances, NRL Scheme, CGT including 2019 rules, CIV elections (transparent/exempt), residence, offshore funds/attribution, ATED

An offshore unauthorised property unit trust provides a means to hold UK real estate as an investment. These trusts are most often set up in the Channel Islands—typically Jersey or Guernsey—or in the Isle of Man, though they can also be constituted under the laws of another non-UK jurisdiction. This Practice Note describes such property unit trusts, wherever formed, as JPUTs (reflecting the prevalence of Jersey property unit trusts). For the purposes of this Practice Note, it is assumed that a JPUT holds UK real estate as an investment and not as trading stock. For an explanation of that distinction, see Practice Note: Dealing in property or property investment? Historically, JPUTs were favoured because UK real estate could be transferred into a JPUT without incurring stamp duty land tax (SDLT). That treatment arose under a specific exemption called ‘seeding relief’, which was withdrawn with effect from 22 March 2006, as noted in Practice Note...

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PRACTICE NOTES
Private Client Glossary (England and Wales): Wills, Probate, Trusts, Capacity and UK Taxation

Private Client England & Wales glossary A Abatement When, after settling the deceased’s funeral costs, debts and liabilities, the remaining estate cannot satisfy all legacies in full, the gifts are reduced accordingly, unless the Will shows a different intention. In a solvent estate, the order for reduction appears in Part II of Schedule 1 to the Administration of Estates Act 1925. Refer to Practice Note: Payment of legacies. Accruals basis Where income is taxed on an accruals basis, it is attributed to a given tax year by reference to the number of days within that year during which the activity giving rise to the liability accrued. See Practice Note: What is the basis of income tax?. Accumulation and maintenance (A&M) trust A form of non‑interest in possession trust designed to benefit children and young people up to 25, which received favourable inheritance tax treatment between 1975 and 2006. See Practice Note: Accumulation and maintenance trusts—IHT [Archived]. Accredited Legal Representative (ALR) ...

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PRACTICE NOTES
UK taxation of unauthorised unit trusts: property and trading fund structuring, investor profiles, EUUTs v limited partnerships, JPUTs/offshore companies, SDLT/VAT, and pension fund pooling schemes

This Practice Note outlines the principal practical applications of unauthorised unit trusts (UUTs) and highlights recurring tax considerations in those settings. Unit trusts chiefly operate as investment fund vehicles. As set out in Practice Note: Taxation of unauthorised unit trusts, a UUT is a unit trust that has not been approved by the Financial Conduct Authority under the Financial Services and Markets Act 2000 (FSMA 2000). UUTs are most frequently deployed as property fund vehicles, though they can also serve as trading funds and as ‘pension fund pooling schemes’. This Practice Note covers: the use of UUTs as property fund vehicles UUTs contrasted with other non- or lightly regulated property fund vehicles the use of UUTs as trading funds, and a short overview of UUTs as pension fund pooling schemes For the tax position of UUTs and their investors, see Practice Note: Taxation of unauthorised unit trusts. UUTs as property fund vehicles Historically, UUTs have most often been adopted...

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