Keep up to date with the latest tax and structuring news with our expert analysis...


Our investment funds team works across the many different types of collective investment vehicles set up to manage a wide range of investors' money. We advise leading players in the financial services market, particularly with regard to new fund products and services.

Investment funds take various forms, including authorised unit trusts, open-ended investment companies, limited partnerships, offshore trusts and offshore companies. Tax issues are crucial when structuring any investment fund because the client normally wants to ensure that an investment in a fund will not give rise to a higher tax cost for the investor than a direct investment in the fund's underlying investment.

In addition, tax is often an important consideration when implementing various schemes of reconstruction involving investment funds, for example, stamp duty and stamp duty reserve tax issues in connection with the merger of investment funds.

We regularly advise a wide range of investment management businesses on the various tax issues that need to be considered in relation to structuring of investment funds, both at fund and investor level, and provide these clients with innovative and tax-efficient solutions.


Notable deals / highlights

  • Advising on merger of two offshore funds and arranging new legislation to permit the merger of a non-reporting fund with a reporting fund without crystallization of offshore income gains.

  • Advising on methods of mitigating income tax on individual limited partners in property limited partnerships.

  • Advising on conversion of property funds into a PAIF.

  • Advising on all UK tax aspects of merger of UK AIF into subfund of overseas umbrella fund.

  • Forming part of HM Treasury tax group concerning FAIFs.

  • Working with HM Revenue & Customs on an industry practitioners' sub-committee considering the implementation of FATCA in the UK.

  • Presenting a panel session with the IRS concerning FATCA at the 24th Annual Conference on the Globalisation of Investment Funds (2013).

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