UK: Final regulations implementing new reserved investor fund

Implementation of new fund beginning March 19, 2025

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March 6, 2025

The government on February 25, 2025, published the final version of the Co-ownership Contractual Schemes (Tax) Regulations 2025 which implement the new reserved investor fund (RIF) beginning March 19, 2025.

The RIF is a new UK unauthorized contractual scheme fund aimed at professional and institutional investors. The RIF is expected to be a suitable vehicle to hold UK real property, particularly commercial property, but the government has confirmed that the fund will be able to invest in a wide range of asset classes beyond real estate.

A qualifying RIF is not subject to tax on its income or gains and is transparent such that income is treated as arising directly to the unit holders. Investors are only subject to tax on gains on disposal of units in the RIF that fall within the scope of UK tax on capital gains.

The final regulations include much of the detail of the draft regulations released last year for consultation.

Read a March 2025 report prepared by the KPMG member firm in the UK

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