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Jurisdiction(s):
United Kingdom
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Key definition
PAIF definition

What does PAIF mean? In legal practice, a PAIF (Property Authorised investment Fund) is an authorised open‑ended investment company (OEIC) used to hold predominantly real estate assets or shares in UK REITs and comparable non‑UK REIT‑type vehicles, with tax treatment broadly aligned to the UK REIT regime at fund level. The PAIF regime is established in UK tax legislation and FCA rules and guidance, and applies consistently across England & Wales, Scotland and Northern Ireland; it is not a concept in Irish law. To qualify, the fund must be an OEIC, meet conditions on investment mix, business activities, ownership (including genuine diversity...

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UK PAIF regime: breach notifications, HMRC termination, voluntary and automatic exit triggers, and corporation tax consequences on leaving

Published by a LexisNexis Tax expert
Practice notes
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The tax regime for property authorised investment funds (paifs)

The PAIF tax framework applies to UK open-ended investment companies (OEICs) that satisfy specified criteria. In some cases, falling short of these requirements can result in removal from the PAIF regime, while a PAIF may equally opt to depart voluntarily. The outcome of any failure hinges on the precise condition involved and, in certain instances, whether the failure is a repeat occurrence. The PAIF conditions are explained in detail in Practice Note: PAIFs—the conditions.

This Practice Note covers:

  • what follows when one or more PAIF conditions are not met, and
  • the tax consequences of an exit from the PAIF regime

For a high-level summary of the overall PAIF framework, see Practice Note: Tax and property funds—overview. For the tax treatment of PAIFs and their investors, alongside associated compliance requirements, see Practice Note: PAIFs—tax treatment of the fund and its investors. The statutory rules for PAIFs are contained in the Authorised Investment Funds (Tax) Regulations 2006 (SI 2006/964), which this Practice Note calls the AIF Tax Regulations...

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Martin Shah
Martin Shah chambers

Martin is a partner in the corporate tax group at Simmons & Simmons. His broad based practice encompasses financial markets, corporate, real estate (including structured real estate) and commercial work, with an emphasis on clients in the asset management & investment funds and financial institutions sectors. His focus includes advising on funds and other investment products, together with structural tax issues for asset management, banking and insurance clients.Martin leads the financial services tax practice which won European Financial Services Tax Team of the Year at the International Tax Review European Awards in 2011 and 2013. He is rated in the latest Legal 500 and Chambers directories ("very strong" in his defence of clients’ interests and can be relied upon to be "robust in difficult circumstances") for corporate tax and endorsed by PLC Which Lawyer?.Martin is a regular participant at the...

Web page updated on 22/05/2026

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