UK: HMRC guidance on new reserved investor fund

Technical note on new reserved investor fund (RIF)

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October 2, 2025

HM Revenue & Customs (HMRC) on September 17, 2025, published a technical note on the new reserved investor fund (RIF) providing guidance in respect of understanding and applying the RIF legislation that came into force earlier this year. Read TaxNewsFlash

The RIF is a new UK unauthorised 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 fund is able to invest in a wide range of asset classes beyond real estate.

The new guidance broadly follows the order of the RIF legislation and expands on its content as well as providing some illustrative worked examples. HMRC have also developed an online form for a scheme operator or agent to apply electronically for a fund to enter the RIF regime. Alternatively, HMRC have published an RIF entry notification form that can also be completed and emailed or posted to them.

HMRC also published additional online forms in respect of notification of changes in the conditions to HMRC that must be met by a RIF and providing RIF annual reports to HMRC.

HMRC confirmed that this RIF guidance will be incorporated into the HMRC investment funds manual in the future.

Read an October 2025 report prepared by the KPMG member firm in the UK

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