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 investment trusts: breach classification, HMRC notification duties and loss or reinstatement of approved status under CTA 2010 and the Investment Trust Regulations (SI 2011/2999)

Published by a LexisNexis Tax expert

Practice notes

To secure, and then retain, approval as an Investment trust for UK tax, a company must meet specific eligibility tests set out in the Corporation Tax Act 2010 (CTA 2010), and comply with a range of continuing obligations under the Investment Trust (Approved Companies) Tax Regulations, SI 2011/2999 (the Investment Trust Regulations). For further detail on those tests and obligations, see Practice Note: Tax and investment trusts—what are investment trusts? This Practice Note explains the consequences where an approved investment trust breaches any of those eligibility tests or does not satisfy one or more of the continuing obligations. It also describes the position where an approved investment trust submits returns on the footing that it is not an approved investment trust for tax purposes. For guidance on applying for investment trust approval, see Practice Note: Tax and investment trusts—applying for HMRC approval. For the taxation of approved investment trusts and their investors, see Practice Note: Tax and investment trusts—tax treatment of the fund and its investors.

Breaches of eligibility conditions vs breaches of ongoing Requirements

Breaches of the CTA 2010 eligibility criteria and breaches of the Investment Trust Regulations’ ongoing requirements are dealt with in different ways by HMRC accordingly...

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Michael Alliston

Norton Rose Fulbright

Michael Alliston is a tax lawyer based in London. He advises on a wide range of corporate tax matters, including M&A, corporate reorganizations, capital markets transactions and financings.Michael's practice comprises a mix of transactional and stand-alone advisory work. He assists companies across a wide variety of sectors, including energy, infrastructure, financial institutions, funds, real estate and transport.Michael has particular experience advising M&A and tax risk underwriters....

Web page updated on 22/05/2026

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