Contractual schemes

FORTHCOMING CHANGE relating to CoACS: On 2 April 2024, the government published draft regulations for consultation which (in addition to providing the tax rules for the new reserved investor fund) make minor changes to the tax rules for co-ownership authorised contractual schemes (CoACS) to ensure that those rules work as intended, and to address points raised through the reserved investor fund policy consultation. The consultation closes on 14 May 2024.

What is an authorised contractual scheme (ACS)?

An authorised contractual scheme (ACS) is a type of authorised collective investment scheme that was introduced in 2013 with the aim of providing a UK alternative to the genuinely tax-transparent authorised fund structures that were available in other jurisdictions, such as Luxembourg and Ireland.

ACSs are authorised and regulated in broadly the same way as UK authorised funds structured as authorised unit trusts (AUTs) and open-ended investment companies (OEICs) (known together in the tax world as AIFs), but are quite different from AIFs as regards their legal form and tax status.

An ACS is essentially a pool of assets held by a depositary and managed on behalf

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