Taxation of Funds

On Wednesday the 11th September I attended an ILAG tax forum on fund taxation.  The event was hosted by Deloitte with sections on corporate streaming, abolition of bond fund rules and tax transparent funds (TTFs).  Speakers were Eliza Dungworth, Nathan Powell and Gavin Bullock.  All very good of course although much of what was covered would be familiar to readers of this blog.  Some useful snippets.

• There seems to be a broad based opposition to HMRC's proposals on corporate streaming and bond funds.  It was mentioned that approaches had been made to HMRC prior to the consultation over whether the bond fund rules could be simplified (i.e. at present if a fund meets the qualifying investments test for one day of a companies accounting period then the company has to treat the fund as a loan relationship which is quite onerous for funds that are close to the 60% cut off)

• There was a reference to life insurers being interested in TTFs as a way of collectivizing existing property holdings (presumably in the way that JPUT's used to be used.)  I would have felt SDLT would have been a big stumbling block - is there a way around?

• Although not covered in the presentations I understand that HMRC have indicated that if they did abolish corporate streaming they would also do something to relax the 10% limit on holdings in a PAIF for life insurers.  My post of 4th September covers this point

This article is by richard bentley - see lifeassurancetax.blogspot.com
LifeAssuranceTax. blogspot.com