Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Investment definition

What does Investment mean? In practice, investment describes an asset or bundle of rights committed in a host state with the aim of generating a return. In investor-state work, the operative definition is treaty-specific: most bilateral investment treaties (BITs) and the Energy Charter Treaty use broad, asset-based lists covering, where applicable, tangible and intangible property located in the territory, shareholdings and other equity interests, contractual rights (including concessions), intellectual property, and loans or claims to money, subject to stated carve-outs. The ICSID Convention does not define investment; tribunals assess jurisdiction by the treaty text and case law, commonly considering a contribution of resources,...

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

Published by a LexisNexis Tax expert

Practice notes

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...

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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...

Web page updated on 22/05/2026

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