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United Kingdom
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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,...

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UK tax and regulatory overview of authorised investment funds (AUTs and OEICs), including UCITS, NURS, QIS, LTAF, PAIFs, TEFs, unit classes and umbrella funds

Published by a LexisNexis Tax expert
Practice notes
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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...

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Camilla Spielman
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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