Legalize / United Kingdom / Statutory-Instrument

The Co-ownership Contractual Schemes (Tax) Regulations 2025

Type Statutory-Instrument

Publication 2025-02-24

State In force

Department King's Printer of Acts of Parliament

Source legislation.gov.uk

PDF Download

articles Not indexed

Reform history JSON API

“umbrella co-ownership scheme” means a co-ownership scheme— which provides arrangements for the separate pooling of the contributions of the participants and the profits and income out of which payments are to be made to them, and under which the participants are entitled to exchange rights in one pool for rights in another;

“umbrella RIF” means an umbrella co-ownership scheme which is a RIF.

Umbrella schemes: restriction requirement

42

(1) An umbrella co-ownership scheme meets the restriction requirement under regulation 10 at any time when each sub-scheme of the scheme meets at least one of the restriction conditions.

(2) Accordingly, references to a co-ownership scheme in regulations 11 to 14 are to be read as if they were references to a sub-scheme of the umbrella co-ownership scheme.

(3) Regulation 15 applies as if—

(a) it provided that an umbrella RIF’s status as a RIF is unaffected by virtue of a change in which of the restriction conditions any of its sub-schemes meets at any time (so long as each sub-scheme continues to meet at least one of those conditions),

(b) paragraph (3) applied where—

(i) a RIF’s status as such has at any time depended on one of its sub-schemes meeting the UK property rich condition,

(ii) the sub-scheme ceases to meet that condition at a particular time, and

(iii) on ceasing to meet that condition, it meets the non-UK property assets condition, and

(4) Regulation 18 applies as if—

(a) the reference in paragraph (1) to a RIF breaching the restriction requirement were a reference to an umbrella RIF breaching the restriction requirement as a result of a sub-scheme (the “relevant sub-scheme”) of the RIF ceasing to meet at least one of the restriction conditions,

(b) the deemed disposal of units under paragraph (4), were a deemed disposal of units in the relevant sub-scheme by the participants in that sub-scheme and the duty imposed on the operator by paragraph (5) to notify the participants of the deemed disposal is to be read accordingly, and

(c) the reference in paragraph (6) to a breach of the restriction requirement by virtue of a RIF ceasing to meet the exempt investor condition were a reference to a breach of the restriction requirement by an umbrella RIF by virtue of a sub-scheme of the RIF ceasing to meet the exempt investor condition.

Umbrella schemes: becoming a Reserved Investor Fund (Contractual Scheme)

43

(1) Regulation 4 applies in relation to an umbrella co-ownership scheme as if the requirement in paragraph (1)(d) were a requirement to set out which restriction condition is met by each of the sub-schemes of the umbrella co-ownership scheme.

(2) Regulation 13 applies in relation to an umbrella co-ownership scheme as if it provided for the scheme to rely on the application of that regulation as modified below to enable a sub-scheme of the scheme to meet the UK property rich condition for the purposes of the scheme becoming a RIF (but see paragraph (4)).

(3) In such a case—

(a) regulation 13 applies as if references to “a co-ownership scheme” were references to a sub-scheme of an umbrella co-ownership scheme (except for those references that relate to an entry notice in relation to the scheme), and

(b) the requirements of paragraph (1) of regulation 13 apply as if references to “the scheme” in sub-paragraphs (a) to (c) were references to “the sub-scheme”.

(4) An umbrella co-ownership scheme may not rely on regulation 13 in relation to a sub-scheme of the scheme if—

(a) the scheme has previously been a RIF (including an umbrella RIF),

(b) the scheme has previously been an authorised contractual scheme, or

(c) the sub-scheme has participants that have been issued with units in the sub-scheme in return for consideration other than money.

Umbrella schemes: ceasing to be a Reserved Investor Fund (Contractual Scheme)

44

(1) Regulation 19 does not apply in relation to an umbrella RIF.

(2) But regulation 19 applies to a sub-scheme of an umbrella RIF where the sub-scheme ceases to meet the UK property rich condition, as if any reference in that regulation to RIF was a reference to sub-scheme of an umbrella RIF.

(3) Where regulation 19 applies to a sub-scheme of an umbrella RIF, regulation 26 applies as if the first reference to RIF in paragraph (1) and the reference to RIF in paragraph 7(a)(i) were a reference to sub-scheme of an umbrella RIF.

Umbrella schemes: additional notification requirements

45

(1) The operator of an umbrella RIF must notify HMRC if—

(a) a sub-scheme of the RIF is wound up, or

(b) a new sub-scheme of the RIF is established.

(2) A notice—

(a) under paragraph (1) must be submitted to HMRC within a period of 30 days, beginning with the day on which the event in paragraph (1) occurred;

(b) under paragraph (1)(b) must additionally include which of the restriction conditions is met by the new sub-scheme.

Chapter 12 — Investment in offshore funds

Interpretation: Chapter 12

46

In this Chapter “non-reporting fund”, “reportable income”, “reported income” and “reporting fund” have the same meanings as in the 2009 Regulations[^f00037].

Investments in reporting offshore funds

47

(1) This regulation applies if a RIF has made an investment for its purposes in a reporting fund.

(2) The excess, if any, of the reported income of the reporting fund in respect of the investment over the amount distributed by the reporting fund in respect of that investment is treated for income tax and corporation tax purposes as additional income of the participants in the RIF in proportion to their rights in the RIF.

(3) If the reporting fund does not make a report available in accordance with regulation 90(5) of the 2009 Regulations—

(a) the operator of the RIF must estimate the amount of excess (if any) of the reportable income of the reporting fund in respect of the investment over the amount distributed by the reporting fund in respect of that investment, and

(b) the estimated amount is treated for income tax and corporation tax purposes as additional income of the participants in the RIF in proportion to their rights in the RIF.

(4) Where paragraph (3) applies, in the first accounting period in which the operator has sufficient information to accurately determine the amount of any excess estimated under that paragraph, the operator must make any necessary corrections by adjusting the estimated amount for that accounting period.

(5) The additional income is treated as arising on the information reporting date in respect of the accounting period in which the excess is treated as made under the 2009 Regulations.

Investments in non-reporting offshore funds: first case

48

(1) This regulation applies if—

(a) a RIF has made an investment for its purposes in a non-reporting fund, and

(b) the conditions in paragraph (2) are met for an accounting period.

(2) The conditions are that—

(a) the RIF has access to the accounts of the non-reporting fund,

(b) the RIF has sufficient information about the non-reporting fund to enable it to prepare a computation of reportable income for the fund, and

(c) the RIF can reasonably expect to rely on continued access to that information for the period in which it will hold the investment in the fund.

(3) The amount that would be the excess, if any, of the reportable income of the non-reporting fund in respect of the investment over the amount distributed by the non-reporting fund in respect of that investment is treated for income tax and corporation tax purposes as additional income of the participants in the RIF in proportion to their rights in the RIF.

(4) The additional income is treated as arising on the information reporting date in respect of the accounting period to which the excess relates.

Investments in non-reporting offshore funds: second case

49

(1) This regulation applies if a RIF has made an investment for its purposes in a non-reporting fund, but the conditions in regulation 48 (2) are not met for an accounting period.

(2) The increase in fair value of the investment in the non-reporting fund in that period is treated for income tax and corporation tax purposes as additional income of the participants in the RIF in proportion to their rights in the RIF.

(3) Decreases in the fair value of that interest in earlier accounting periods may be set against the increase referred to in paragraph (2) to reduce the amount of the increase, but—

(a) not to below zero, and

(b) only to the extent that the decreases in fair value have not previously had the effect of reducing the amount of a fair value increase.

(4) The additional income is treated as arising on the information reporting date in respect of the accounting period in which the fair value increase arises.

(5) In this regulation “fair value” in relation to an interest in a non-reporting fund means the amount which, at the time the value is to be determined, is the amount for which the interest could be exchanged between knowledgeable and willing parties dealing at arm’s length.

Part 3 — Co-ownership contractual schemes: amendments to relevant legislation

Chapter 1 — Finance Act 1986 and Finance Act 1999

Stamp duty reserve tax: exceptions

50

In section 90 of FA 1986[^f00038]—

(a) in subsection (7B)—

(i) in paragraph (a)(i) for “an authorised” substitute “a co-ownership”,

(ii) for paragraph (a)(ii) substitute—

(ii) in relation to a co-ownership contractual umbrella scheme, on transfers between sub-schemes;

, and

(iii) in paragraph (b) for “an authorised” substitute “a co-ownership”;

(b) after subsection (7B) insert—

(7BA) In subsection (7B) and this subsection— - “authorised contractual scheme” has the meaning given in section 237(3) of the Financial Services and Markets Act 2000[^f00039]; - “co-ownership contractual scheme” means— an authorised contractual scheme, or a Reserved Investor Fund (Contractual Scheme); - “co-ownership contractual umbrella scheme” means a co-ownership contractual scheme— which provides arrangements for separate pooling of the contributions of participants and of the profits or income out of which payments are to be made to them, and under which the participants are entitled to exchange rights in one pool for rights in another; - “depositary” has the meaning given in section 237(2) of the Financial Services and Markets Act 2000; - “Reserved Investor Fund (Contractual Scheme)” has the meaning given by section 20 of the Finance (No.2) Act 2024; - “sub-scheme”, in relation to a co-ownership contractual umbrella scheme, means such of the arrangements as relate to a separate pool; - “units” has the meaning given in section 237(2) of the Financial Services and Markets Act 2000.

Stamp duty: exemptions

51

Paragraph 25A of Schedule 13 to FA 1999[^f00040] is amended as follows—

(a) in sub-paragraph (1) in the words before paragraph (a) omit “on”;

(b) in sub-paragraph (1)(a)—

(i) at the beginning insert “on”, and

(ii) for “an authorised” substitute “a co-ownership”;

(b) in relation to a co-ownership contractual umbrella scheme, on transfers between sub-schemes;

(d) in sub-paragraph (1)(c)—

(i) at the beginning insert “on”, and

(ii) for “an authorised” substitute “a co-ownership”;

(e) after sub-paragraph (1) insert—

(1A) In sub-paragraph (1) and this sub-paragraph— - “authorised contractual scheme” has the meaning given in section 237(3) of the Financial Services and Markets Act 2000; - “co-ownership contractual scheme” means— an authorised contractual scheme, or a Reserved Investor Fund (Contractual Scheme); - “co-ownership contractual umbrella scheme” means a co-ownership contractual scheme— which provides arrangements for separate pooling of the contributions of participants and of the profits or income out of which payments are to be made to them, and under which the participants are entitled to exchange rights in one pool for rights in another; - “depositary” has the meaning given in section 237(2) of the Financial Services and Markets Act 2000; - “Reserved Investor Fund (Contractual Scheme)” has the meaning given by section 20 of the Finance (No.2) Act 2024; - “sub-scheme”, in relation to a contractual umbrella scheme, means such of the arrangements as relate to a separate pool; - “units” has the meaning given in section 237(2) of the Financial Services and Markets Act 2000.

(f) omit sub-paragraph (2).

Chapter 2 — Taxation of Chargeable Gains Act 1992

Collective investment schemes

52

(1) TCGA 1992[^f00041] is amended as set out in this regulation and in regulations 53 and 54.

(2) In section 99A(6) (treatment of umbrella schemes), after paragraph (a) insert—

(aa) a Reserved Investor Fund (Contractual Scheme),

(3) In section 103D (application of Act to tax transparent funds)—

(a) in subsection (1), in the definition of “tax transparent fund”—

(i) at the end of paragraph (a) omit “or”,

(ii) at the end of that paragraph insert—

(aa) a Reserved Investor Fund (Contractual Scheme), or

(b) in subsection (2)—

(i) at the end of the definition of “authorised contractual scheme” omit “and”, and

(ii) after the definition of “co-ownership scheme” insert “, and

“Reserved Investor Fund (Contractual Scheme)” has the meaning given by section 20 of the Finance (No.2) Act 2024.

(4) After section 103DB insert—

(103DC) (1) The assets of a co-ownership scheme, which is not a tax transparent fund or an offshore collective investment vehicle, are treated for the purposes of tax in respect of chargeable gains as held by the participants in the scheme as partners. (2) Any dealings by the operator of a such a scheme are treated for those purposes as dealings by the participants in the scheme in partnership. (3) If a participant is entitled to an allowance under Part 2A of CAA 2001 (structures and buildings allowances) by reference to expenditure in relation to their interest in such a scheme, that allowance is not to be disregarded for the purposes of the application of section 37B (exclusion of certain expenditure: structures and buildings allowances) in relation to a disposal of their interest. (4) Where— (a) expenditure has been made in respect of the assets of such a scheme, and (b) a capital allowance or renewals allowance (within the meaning of section 41(4) or (5)) has been given to a participant in the scheme in relation to that expenditure, the capital allowance or renewals allowance that was given to the investor is to be excluded from the sums allowable as a deduction in computing the amount of a loss accruing to the participant in relation to a disposal of their interest in the assets of the scheme. (5) Subsections (6) and (7) apply for the purposes of this Act at any time that a co-ownership scheme, which is not a tax transparent fund or an offshore collective investment vehicle, becomes an authorised contractual scheme or a Reserved Investor Fund (Contractual Scheme) (a “relevant scheme”). (6) Each participant in the co-ownership scheme is deemed to, immediately before the time that the scheme becomes a relevant scheme, have sold their interest in the assets held by the participants in the scheme as partners at its market value at that time. (7) Each participant is treated as having acquired their units in the relevant scheme— (a) at the time the co-ownership scheme becomes a relevant scheme, and (b) at their market value at that time. (8) For the purposes of this section, a participant’s interest in the assets held by the participants of a co-ownership scheme as partners is a just and reasonable proportion of the assets having regard to the participant’s units in the scheme. (9) In this section— - “offshore collective investment vehicle” has the meaning it has in Schedule 5AAA (see paragraph 2 of that Schedule); - “tax transparent fund” has the meaning it has in section 103D. (10) In subsection (1), the reference to the assets of a co-ownership scheme is a reference to assets which are subject to the scheme.

(5) In section 103E(1) (application of Chapter), after paragraph (a) insert—

(aa) a Reserved Investor Fund (Contractual Scheme),

(6) In section 211B(1) (transfers of assets to certain collective investment schemes)—

(a) at the end of paragraph (a)(i) omit “or”,

(b) after that paragraph insert—

(ia) a Reserved Investor Fund (Contractual Scheme), or

(7) In section 212 (annual deemed disposal of holdings of unit trusts etc.)—

(a) in subsection (1), after paragraph (ba) insert—

(bb) units in a Reserved Investor Fund (Contractual Scheme), or

, and

(b) after subsection (1) insert—

(1A) For the purposes of computing the gain accruing on a deemed disposal under subsection (1) of units in an authorised contractual scheme which is a co-ownership scheme or of units in a Reserved Investor Fund (Contractual Scheme), subsections (3A) and (9) of section 103D (application of Act to tax transparent funds) do not apply. (1B) But subsection (1A) does not affect the application of those subsections in the event of any other disposal of units in such a scheme by an insurance company, and in such a case— (a) section 103D(3A) applies in respect of all allowances under Part 2A of CAA 2001 to which the company has been entitled during the period it has held units in the scheme, and (b) section 103D(9) applies in respect of all capital allowances and renewal allowances that have been, or may be, made to expenditure incurred during that period.

(8) In section 288(8) (interpretation), in the table, at the appropriate place insert—

“Reserved Investor Fund (Contractual Scheme)”	s 103D(2)

Property rich collective investment vehicles

53

(1) Schedule 5AAA to TCGA 1992[^f00042] is amended as follows.

(2) In the italic heading before paragraph 5 for “a CoACS” substitute “certain co-ownership schemes”.

(3) In paragraph 5(1) after “co-ownership scheme” insert “, or a Reserved Investor Fund (Contractual Scheme),”.

(4) In paragraph 12—

(a) in sub-paragraph (3)(a) after “CoACS” insert “or a RIF”,

(b) in sub-paragraph (4)(b) after “CoACS”, in both places it occurs, insert “or RIF”, and

“RIF” means a Reserved Investor Fund (Contractual Scheme).

(5) In paragraph 21(5)(a) after “CoACS”, in both places it occurs, insert “or RIF”.

(6) In paragraph 33(1)—

(a) after paragraph (a) insert “,

(aa) a RIF (within the meaning of paragraph 12) that meets the UK property rich condition in regulation 12 of the Co-ownership Contractual Schemes (Tax) Regulations 2025.

, and

(b) in the words after paragraph (d), after “transparent fund,” insert “the RIF,”.

Exemptions for disposals by companies with substantial shareholding

54

(1) Schedule 7AC to TCGA 1992[^f00043] is amended as follows.

(2) In paragraph 3B (subsidiary exemption: qualifying institutional investors)—

(a) in sub-paragraph (4)(b)—

(i) the words from the first “as” to the end become sub-paragraph (i), and

(ii) after that sub-paragraph insert—

(ii) as including an exempt Reserved Investor Fund (Contractual Scheme) (and references to ordinary share capital, in the case of such a scheme, as references to units in the scheme).

(b) after sub-paragraph (6) insert—

(6A) Sub-paragraph (6) does not apply in relation to a co-ownership scheme which is treated as a partnership under section 103DC (co-ownership schemes which are to be treated as partnerships).

(7) In this Schedule— - “exempt Reserved Investor Fund (Contractual Scheme)” means a Reserved Investor Fund (Contractual Scheme) which meets the exempt investor condition in regulation 14 of the Co-ownership Contractual Schemes (Tax) Regulations 2025; - “exempt unauthorised unit trust” has the same meaning as in regulation 3 of the Unauthorised Unit Trusts (Tax) Regulations 2013 [^f00044].

(3) In paragraph 30A(1) (meaning of qualifying institutional investor), at the end insert—

(H) Exempt Reserved Investor Fund (Contractual Scheme) Exempt Reserved Investor Fund (Contractual Scheme) (within the meaning given by paragraph 3B(7)).

Chapter 3 — Capital Allowances Act 2001

Plant and machinery allowances

55

(1) Part 2 of CAA 2001[^f00045] is amended as follows.

(2) In the italic heading before section 262AA omit “authorised”.

(3) In section 262AA(1) and (4) (co-ownership schemes: carrying on qualifying activity) omit “authorised”.

(4) Section 262AB (co-ownership schemes: election) is amended as follows—

(a) in subsection (1) omit “authorised”;

(b) in subsection (3)(b) after “2017” insert “in the case of a co-ownership contractual scheme which is a co-ownership authorised contractual scheme, or the date on which the Co-ownership Contractual Schemes (Tax) Regulations 2025 come into force in the case of a co-ownership contractual scheme which is a Reserved Investor Fund (Contractual Scheme)”;

(d) after subsection (5) insert—

(5A) An election under this section in respect of a Reserved Investor Fund (Contractual Scheme) continues unaffected for so long as the scheme is— (a) a Reserved Investor Fund (Contractual Scheme), (b) a co-ownership authorised contractual scheme, or (c) an unauthorised co-ownership contractual scheme, and the application of this Chapter in respect of the scheme is not affected by any change in the nature of the scheme so long as it remains of a type set out in paragraphs (a) to (c).

(5) In section 262AC(1) and (4) (co-ownership schemes: calculation of allowance after election) omit “authorised”.

(6) In section 262AD(1) (co-ownership: effect of election for participants) omit “authorised”.

(7) In section 262AE(1) (co-ownership schemes: effect of election for purchasers) omit “authorised”.

(8) Section 262AEA (co-ownership schemes: withdrawal of election) is amended as follows—

(a) in the heading, after “Co-ownership” insert “authorised contractual”;

(b) in subsection (1)(a) for “the”, the first time it occurs, substitute “a co-ownership authorised contractual”.

(9) In section 262AF (co-ownership schemes: definitions relating to schemes)—

(a) in the definition of “operator” and “units” omit “authorised”, and

(b) insert the following definitions in the appropriate places—

“co-ownership contractual scheme” means— a co-ownership authorised contractual scheme, or a Reserved Investor Fund (Contractual Scheme);”;

““Reserved Investor Fund (Contractual Scheme)” has the meaning given by section 20 of F(No.2)A 2024;”;

““unauthorised co-ownership contractual scheme” means a co-ownership scheme which is not a co-ownership contractual scheme;

Structures and building allowances

56

(1) Part 2A of CAA 2001[^f00046] is amended as follows.

(2) In the italic heading before section 270IC omit “authorised”.

(3) In section 270IC(1) and (4) (co-ownership schemes: carrying on qualifying activity) omit “authorised”.

(4) In section 270ID (co-ownership schemes: election)—

(a) in subsection (1) after “scheme”, in the first place it occurs, insert “, or a converted Reserved Investor Fund (Contractual Scheme),”, and

(b) after subsection (7) insert—

(7A) In subsection (1)— (a) a “converted Reserved Investor Fund (Contractual Scheme)” means a Reserved Investor Fund (Contractual Scheme) that was previously a co-ownership authorised contractual scheme, and (b) the reference to an election having been made under section 262AB in respect of a converted Reserved Investor Fund (Contractual Scheme) is a reference to such an election having been made in respect of the scheme when it was a co-ownership authorised contractual scheme. (7B) An election under this section in respect of a converted Reserved Investor Fund (Contractual Scheme) is unaffected for so long as the scheme is— (a) a Reserved Investor Fund (Contractual Scheme), (b) a co-ownership authorised contractual scheme, or (c) an unauthorised contractual scheme, and the application of this Chapter in respect of the scheme is not affected by any change to the nature of the scheme so long as it remains of a type set out in paragraphs (a) to (c).

(5) In section 270IE(1) and (4) (co-ownership schemes: calculation of allowance after an election) omit “authorised”.

Chapter 4 — Finance Act 2003

Stamp duty land tax: contractual schemes

57

(1) FA 2003[^f00047] is amended as follows.

(2) In section 102A (co-ownership authorised contractual schemes)[^f00048]—

(a) in the heading omit “authorised”;

(b) in subsection (2) omit “authorised”;

(2A) In this Part, a “co-ownership contractual scheme” means— (a) a co-ownership authorised contractual scheme, or (b) a Reserved Investor Fund (Contractual Scheme).

(d) in subsection (3)—

(i) for “umbrella COACS” substitute “umbrella scheme”, and

(ii) omit “authorised”;

(e) in subsection (4) for “COACS” substitute “scheme”;

(f) in subsection (5)—

(i) for “COACS”, in both places it occurs, substitute “scheme”, and

(ii) omit “authorised”;

(g) in subsection (6) for “COACS” substitute “scheme”;

(h) in subsection (8), after the definition of “co-ownership scheme” insert—

“Reserved Investor Fund (Contractual Scheme)” has the meaning given by section 20 of the Finance (No.2) Act 2024.

(i) in subsection (9) after “contractual scheme” insert “or a Reserved Investor Fund (Contractual Scheme)”;

(j) in subsection (10) omit “authorised”;

(k) in subsection (11) omit “authorised”;

(l) in subsection (12), in paragraph (a) of the definition of “operator” omit “authorised”.

(3) In section 118(2) (meaning of “market value”)[^f00049] for “COACS” substitute “co-ownership scheme”.

(4) In section 122 (index of defined expressions)[^f00050]—

(a) in the table, in the first column for “COACS seeding relief” substitute “co-ownership scheme seeding relief”, and

(b) at the appropriate places insert—

co-ownership contractual scheme	section 102A”;
“Reserved Investor Fund (Contractual Scheme)	section 102A

(5) In paragraph 2(6)(da) of Schedule 4A (stamp duty land tax: higher rate for certain transactions)[^f00051] for “COACS” substitute “co-ownership scheme”.

(6) Schedule 9A (increased rates for non-resident transactions)[^f00052] is amended as follows.

(7) In paragraph 7(4)(a) omit “authorised”.

(8) In the italic heading before paragraph 15 omit “authorised”.

(9) In paragraph 15, after sub-paragraph (2) insert—

(3) A Reserved Investor Fund (Contractual Scheme) is not “non-resident” in relation to any chargeable transaction.

(10) In paragraph 11 of Schedule 17A (further provisions relating to leases)[^f00053]—

(a) in sub-paragraph (3)(ba) for “COACS” substitute “co-ownership scheme”;

(b) in sub-paragraph (4) for “COACS” substitute “co-ownership scheme”;

(i) for “COACS” substitute “co-ownership scheme”, and

(ii) omit “authorised”;

(d) in sub-paragraph (6) for “COACS” substitute “co-ownership scheme”;

(e) in sub-paragraph (7) for “COACS”, in both places it occurs, substitute “co-ownership scheme”.

Stamp duty land tax: seeding relief

58

(1) Part 4 of FA 2003[^f00054] is amended as follows.

(2) In section 65A (PAIF seeding relief and COACS seeding relief)—

(a) for the heading substitute “Seeding relief”;

(b) in subsection (2)(b) for “(COACS seeding relief)” substitute “and Reserved Investor Funds (Contractual Schemes) (co-ownership scheme seeding relief)”;

(i) in the words before paragraph (a), for “COACS” substitute “co-ownership scheme”;

(ii) in paragraph (a), after “scheme” insert “or a Reserved Investor Fund (Contractual Scheme)”;

(d) after subsection (6) insert—

(7) Co-ownership scheme seeding relief may not be claimed where the purchaser is a Reserved Investor Fund (Contractual Scheme) if the scheme— (a) has previously claimed such relief, and (b) following that claim ceased, at any time, to be a Reserved Investor Fund (Contractual Scheme).

(3) Section 81 (further return where relief withdrawn) is amended as follows—

(a) in subsection (1)(bb) for “COACS” substitute “co-ownership scheme”;

(b) in subsection (1A)(c) for “COACS” substitute “co-ownership scheme”;

(i) in paragraph (g) for “COACS” substitute “co-ownership scheme”;

(ii) in paragraph (h) for “COACS” substitute “co-ownership scheme”;

(d) in subsection (4)(bb)—

(i) for “COACS” substitute “co-ownership scheme”, and

(ii) in sub-paragraph (i), omit “authorised”.

(4) In section 86 (payment of tax)—

(a) in subsection (2)(bb) for “COACS” substitute “co-ownership scheme”;

(b) in subsection (5)—

(i) omit the “and” at the end of paragraph (a), and

(ii) after paragraph (b) insert “, and

(c) regulation 31 of the Co-ownership Contractual Schemes (Tax) Regulations 2025 (withdrawal of seeding relief: application to postpone payment of tax where appeal against relevant decisions).

(5) In section 87 (interest on unpaid tax)—

(a) in subsection (1A), after “(c)” insert “or section 87A(4) or (6)”;

(b) in subsection (3)(a)(iib), (azc) and (azd) for “COACS” substitute “co-ownership scheme;

(d) at the end of subsection (4), insert “(except in a case to which section 87A applies)”.

(6) After section 87 insert—

(87A) (1) This section makes provision about the meaning of “relevant date” for the purposes of section 87 in the cases set out below where co-ownership seeding relief in relation to a land transaction has been withdrawn under paragraph 13 of Schedule 7A as a result of the purchaser ceasing to be a Reserved Investor Fund (Contractual Scheme) (and, accordingly, ceasing to be a co-ownership contractual scheme). (2) In those cases this section applies instead of section 87(3)(a)(iib) for the purposes of determining the relevant date. (3) The first case is where— (a) the purchaser ceases to be a Reserved Investor Fund (Contractual Scheme) by virtue of breaching the ownership requirement or the restriction requirement, and (b) the effective date of the relevant land transaction fell before the start of the cure period that applied in relation to the breach, and in such a case the “relevant date” is the date on which the breach mentioned in paragraph (a) first occurred. (4) The second case is where— (a) the purchaser ceases to be a Reserved Investor Fund (Contractual Scheme) by virtue of breaching the ownership requirement or the restriction requirement, and (b) the effective date of the relevant land transaction fell within the cure period that applied in relation to the breach, and in such a case the “relevant date” is the effective date of the relevant land transaction. (5) The third case is where— (a) the purchaser ceases to be a Reserved Investor Fund (Contractual Scheme) as a result of ceasing to meet the UK property rich condition in regulation 12 of the 2025 Regulations, and (b) regulation 19 of those Regulations applied in relation to the scheme, and in such a case the “relevant date” means the date on which regulation 19 first applied in relation to the scheme. (6) The fourth case is where— (a) the purchaser ceases to be a Reserved Investor Fund (Contractual Scheme) by virtue of the scheme no longer being able to rely on regulation 9 of the 2025 Regulations to meet the ownership requirement, and (b) the effective date of the relevant land transaction fell at a time when the scheme was relying on that regulation to meet the ownership requirement, and in such a case the “relevant date” means the effective date of the relevant land transaction. (7) In this section— - “the 2025 Regulations” means the Co-ownership Contractual Schemes (Tax) Regulations 2025; - “cure period”— in relation to a breach of the ownership requirement, means— “the 9 month period” that applies in relation to the breach under regulation 16 of the 2025 Regulations (as defined in that regulation), or if a notice is given in relation to the breach under paragraph (2) of that regulation, the period beginning with the day on which the breach occurred and ending on the day on which the notice is given; in relation to a breach of the restriction requirement, means— “the 9 month period” that applies in relation to a breach under regulation 18 of the 2025 Regulations (as defined in that regulation), or if a notice is given in relation to the breach under paragraph (3) of that regulation, the period beginning with the day on which the breach occurred and ending on the day on which the notice is given; - “ownership requirement” has the meaning given in regulation 5 of the 2025 Regulations; - “relevant land transaction” means the land transaction to which the withdrawal of seeding relief relates; - “restriction requirement” has the meaning given in regulation 10 (1) of the 2025 Regulations; - “UK property rich condition” has the meaning given in regulation 12 of the 2025 Regulations.

Seeding relief: amendments to Schedule 7A

59

(1) Schedule 7A to FA 2003 (PAIF seeding relief and COACS seeding relief)[^f00055] is amended as follows.

(2) For the heading of the Schedule substitute “Seeding relief”.

(3) In the heading to Part 2 of the Schedule omit “authorised”.

(4) In the italic heading before paragraph 10 for “COACS” substitute “Co-ownership scheme”.

(5) In paragraph 10—

(a) in sub-paragraph (1) for “COACS” substitute “co-ownership scheme”,

(b) in sub-paragraph (2) omit “authorised”,

(d) after sub-paragraph (5) insert—

(5A) But condition D is met in a case where the purchaser is a Reserved Investor Fund (Contractual Scheme) only if an entry notice has been given in relation to the scheme on or before the effective date. (5B) In sub-paragraph (5A), “entry notice” has the meaning it has in the Co-ownership Contractual Schemes (Tax) Regulations 2025.

(6) In paragraph 11—

(a) in sub-paragraph (1)(a) omit “authorised”,

(b) in sub-paragraph (2) omit “authorised”, and

(7) In paragraph 12—

(a) in sub-paragraph (1) for “COACS” substitute “co-ownership scheme”,

(b) in sub-paragraph (2)—

(i) for “COACS” substitute “Co-ownership scheme”, and

(ii) omit “authorised”,

(i) for “COACS” substitute “Co-ownership scheme”, and

(ii) omit “authorised”, and

(d) in sub-paragraph (4) for “COACS” substitute “Co-ownership scheme”.

(8) In the italic heading before paragraph 13 omit “authorised”.

(9) In paragraph 13—

(a) in sub-paragraph (1)—

(i) for “COACS” substitute “co-ownership scheme”, and

(ii) omit “authorised”,

(b) in sub-paragraph (2) omit “authorised”,

(d) in sub-paragraph (4) omit “authorised”.

(10) In the italic heading before paragraph 14, after “met” insert “by COACS”.

(11) In paragraph 14—

(a) before sub-paragraph (1) insert—

(A1) This paragraph applies where co-ownership scheme seeding relief has been allowed in respect of a transaction (“the relevant transaction”) entered into by— (a) a co-ownership authorised contractual scheme, or (b) a Reserved Investor Fund (Contractual Scheme) that has since become a co-ownership authorised contractual scheme.

(b) in sub-paragraph (1) in the words before paragraph (a), for the words from “COACS” to “and” substitute “, in relation to the relevant transaction,”, and

(12) In paragraph 15—

(a) after sub-paragraph (1) insert—

(1A) Sub-paragraphs (2) to (8) and (9) apply where the relevant transaction was entered into by a co-ownership authorised contractual scheme. (1B) Sub-paragraph (8A) applies where the relevant transaction was entered into by a Reserved Investor Fund (Contractual Scheme) that has since become a co-ownership authorised contractual scheme.

, and

(b) after sub-paragraph (8) insert—

(8A) A co-ownership authorised contractual scheme which at the time of the relevant transaction was a Reserved Investor Fund (Contractual Scheme) meets the genuine diversity of ownership condition at any time that the scheme— (a) meets the genuine diversity of ownership condition under regulation 7 of the Co-ownership Contractual Schemes (Tax) Regulations 2025 (but not solely by virtue of regulation 9 of those Regulations), or (b) meets the non-close condition under regulation 8 of those Regulations (but not solely by virtue of regulation 9 of those Regulations).

(13) In paragraph 16—

(a) in sub-paragraphs (1), (2) and (3) for “COACS” in each place it occurs substitute “co-ownership scheme”,

(b) in sub-paragraph (4) omit “authorised”,

(d) in sub-paragraph (10) for “COACS” substitute “co-ownership scheme”.

(14) In paragraph 17—

(a) in sub-paragraph (1)(a) omit “authorised”,

(b) in sub-paragraph (2)(a) for “COACS” substitute “co-ownership scheme”,

(d) in sub-paragraph (6)—

(i) in the definition of “relevant seeding transaction” omit “authorised”,

(ii) in the definition of “seeding transaction” for “COACS” substitute “co-ownership scheme”, and

(iii) in the definition of “the value of V’s investment in the scheme” omit “authorised”.

(15) In paragraph 18—

(a) in sub-paragraph (1)(a) for “COACS” substitute “co-ownership scheme”,

(b) in sub-paragraph (3) omit “authorised”, and

(16) In paragraph 19(1) and (4) omit “authorised”.

(17) In paragraph 20—

(a) in each place it occurs, omit “authorised”, and

(b) in paragraph (a) of the definition of “units in the co-ownership authorised contractual scheme”, for “COACS” substitute “scheme”.

(18) In paragraph 21—

(a) for ““COACS seeding relief”” substitute ““co-ownership scheme seeding relief””,

(b) in the definition of “co-ownership authorised contractual scheme”, after “(2),” insert “(2A),”, and

(c) in the definitions of “non-qualifying individual”, “operator”, “portfolio test”, “relevant disposal” and “seeding period” omit “authorised”.

Chapter 5 — Income Tax (Trading and Other Income) Act 2005

Personal portfolio bonds: the property categories

60

In section 520 of ITTOIA 2005[^f00056]—

(a) in the table in subsection (2), in the entry in the second column corresponding to the entry “Category 9” in the first column, after “scheme” insert “or a Reserved Investor Fund (Contractual Scheme)”, and

(b) in subsection (4), at the appropriate place, insert—

“Reserved Investor Fund (Contractual Scheme)” has the meaning given by section 20 of F(No.2)A 2024.

Chapter 6 — Corporation Tax Act 2010

Real Estate Investment Trusts

61

(1) CTA 2010[^f00057] is amended as follows.

(2) In section 528(4A) (conditions for company), after paragraph (ba) insert—

(bb) a person acting on behalf of a Reserved Investor Fund (Contractual Scheme) (within the meaning of section 20 to F(No.2)A 2024);”

(3) In paragraph (a) of section 535A(7A) (disposals of rights or interests in UK property rich companies), after “Act)” insert “, or is a Reserved Investor Fund (Contractual Scheme) (within the meaning of section 20 of F(No.2)A 2024)”.

Chapter 7 — The Co-ownership Authorised Contractual Schemes (Tax) Regulations 2017

Amendment of The Co-ownership Authorised Contractual Schemes (Tax) Regulations 2017

62

The Co-ownership Authorised Contractual Schemes (Tax) Regulations 2017[^f00058] are amended as follows—

(a) in regulation 2 (interpretation), after the definition of “HMRC” insert—

“Reserved Investor Fund (Contractual Scheme)” has the meaning given by section 20 of the Finance (No.2) Act 2024.

(b) in regulation 3 (interpretation: Part 2)—

(i) after “to a CoACS” insert “or a Reserved Investor Fund (Contractual Scheme)”;

(ii) after “of the CoACS” insert “or the Reserved Investor Fund (Contractual Scheme)”;

(d) in regulation 5 (information to be provided to other CoACS), in paragraph (1), after “made for the purposes of a CoACS” insert “or Reserved Investor Fund (Contractual Scheme)”;

(e) in regulation 8 (penalty for failing to provide information)—

(i) in paragraph (1), for “£60 for each offence” substitute “£100 for each offence”;

(ii) in paragraph (2), for “£600” substitute “£1000”.

Part 4 — Transitional provision

Application to authorised co-ownership schemes

63

(1) These Regulations will apply in respect of an authorised co-ownership scheme for an accounting period which begins on or after the date on which these Regulations come into force.

(2) But nothing in this regulation prevents these Regulations applying for the purpose of an authorised co-ownership scheme becoming a RIF.

(3) In this regulation, “accounting period” has the meaning given by Chapter 2 of Part 2 of CTA 2009.

Signed

Jeff Smith — Vicky Foxcroft — Two of the Lords Commissioners of His Majesty's Treasury — 24th February 2025

Explanatory note

(This note is not part of the Regulations)

Explanatory Note

These Regulations set out tax rules for a new type of investment fund, the Reserved Investor Fund (Contractual Scheme) (“RIF”), and its investors. In addition, they make minor changes to the tax rules for Co-ownership Authorised Contractual Schemes (“CoACS”), a similar type of investment fund.

Part 2 sets out supplementary qualifying conditions for a RIF (in addition to the conditions contained within section 20 of the Finance (No.2) Act 2024, entry and exit provisions, accounting provisions, information requirements, penalties for failure to give information or requisite notice and umbrella scheme provisions. A penalty under these regulations is determined in accordance with section 100 of the Taxes Management Act 1970 (c. 9).

Part 3 introduces further tax rules for RIFs mainly by amending existing primary legislation related to CoACS to extend the application of those provisions to RIFs or, where relevant, modifying the application of provisions applying to CoACS and RIFs, and in some cases making standalone provision for RIFs where no comparable provision is required for CoACS. The changes address issues that are relevant for RIFs, but also affect CoACS and ensure consistency of application between the two regimes.

Part 4 provides a transitional provision so that the changes introduced by these Regulations will only apply to authorised co-ownership schemes in respect of an accounting period which begins after the Regulations come into force.

A Tax Information and Impact Note covering this instrument was published on 6 March 2024 alongside the Spring Finance Bill 2024 and is available on the GOV.UK website at https://www.gov.uk/government/collections/tax-information-and-impact-notes-tiins. A supplementary Tax Information and Impact Note for this instrument will be published at the same GOV.UK website.

Footnotes

[^f00001]: 1992 c. 12. Section 103C was added by section 36(3) of the Finance Act 2012 (c. 14). Schedule 5AAA was added by paragraph 21 of Schedule 1 to the Finance Act 2019 (c. 1). Section 1C defines what is meant by “UK land” and an “interest in UK land”. Section 288 defines what is meant by “the tribunal”.

[^f00002]: 2017 c. 32. Section 71 defines what is meant by “CAA 2001” and “ITTOIA 2005”.

[^f00003]: 2024 c. 12. Section 20 defines what is meant by a “Reserved Investor Fund (Contractual Scheme)” (or “RIF”), “HMRC”, “authorised co-ownership scheme” and “co-ownership scheme”. Section 25 defines what is meant by “CTA 2009”, “CTA 2010” and “TCGA 1992” and provides that “FA” followed by a year is a reference to the Finance Act for that year.

[^f00004]: S.I. 2009/3001; relevant amending instruments are S.I. 2011/1211, 2013/1411 and 2017/240.

[^f00005]: 2000 c. 8. Relevant amendments were made by S.I. 2013/1388

[^f00006]: Relevant amendments were made to section 237(2) by S.I. 2011/1613, 2013/1388, 2019/325 and paragraph 5 of Schedule 22 to the Financial Services Act 2021 (c. 22).

[^f00007]: Other conditions that a co-ownership scheme must meet are set out in section 20(1)(a) to (c) of F(No.2)A 2024.

[^f00008]: The requirement for a deed to set out the arrangements of the scheme is set out in section 235A(3) of FISMA 2000.

[^f00009]: Relevant amendments were made by paragraph 156 of Schedule 4 to the Co-operative and Community Benefit Societies Act 2014 (c. 14).

[^f00010]: Relevant amendments were made by S.I. 2020/315.

[^f00011]: Relevant amendments were made by paragraph 4 of Schedule 7 to the Finance Act 2024 (c. 3).

[^f00012]: Schedule 1A was inserted by paragraph 14 of Schedule 1 to the Finance Act 2019.

[^f00013]: Relevant amendments were made by S.I. 2020/315.

[^f00014]: Relevant amendments were made by S.I. 2020/315.

[^f00015]: Schedule 5AAA was inserted by paragraph 21 of Schedule 1 to the Finance Act 2019 (c. 1).

[^f00016]: 2012 c. 14.

[^f00017]: Relevant amendments were made by S.I. 2019/689.

[^f00018]: Paragraph 1 was amended by paragraph 4 of Schedule 1 to the Corporation Tax Act 2010 (c. 4).

[^f00019]: Paragraph 8 was amended by section 301 of the Finance Act 2004 (c. 6) and the Scotland Act 2012 (c. 11).

[^f00020]: Section 77 was amended by section 94 of the Finance Act 2008 (c. 9), paragraph 17 of Schedule 3 to the Scotland Act 2012, paragraph 5 of Schedule 39 to the Finance Act 2013 (c. 29) paragraph 9 of Schedule 1 to the Stamp Duty Land Tax Act 2015 (c. 1).

[^f00021]: Section 261D was inserted by S.I. 2013/1388. Relevant amendments were made by S.I. 2018/696.

[^f00022]: Part 4 defines what is meant by “land transaction”, “chargeable consideration”, “chargeable interest” and “market value”.

[^f00023]: Paragraphs 9 to 40 of Schedule 15 were substituted by paragraph 1 of Schedule 41 to the Finance Act 2004 (c. 4).

[^f00024]: Relevant amendments were made by section 297 of, and paragraph 4 of Schedule 39 to, the Finance Act 2004 (c. 12), section 75 of the Finance Act 2007 (c. 11), section 29 of, and paragraph 4 of Schedule 3 to, the Scotland Act 2012 (c. 11), and section 16 of, and paragraph 3 of Schedule 2 to, the Wales Act 2014 (c. 29).

[^f00025]: S.I. 2013/1773, amended by S.I. 2019/328.

[^f00026]: Section 261E was inserted by S.I. 2013/1388.

[^f00027]: Schedule 9A was inserted by paragraph 5 of Schedule 16 to the Finance Act 2021 (c. 26).

[^f00028]: See also subsections (3) to (6) of section 102A. Section 102A was inserted by paragraph 1 of Schedule 16 to the Finance Act 2016 (c. 24).

[^f00029]: Schedule 7A was inserted by paragraph 4 of Schedule 16 to the Finance Act 2016 (c. 24).

[^f00030]: Section 81(1)(bb) was inserted by paragraph 7 of Schedule 16 to the Finance Act 2016.

[^f00031]: Paragraph 39(5) and paragraph 40 were amended by S.I. 2009/56.

[^f00032]: Paragraph 39(1) was amended by S.I. 2009/56.

[^f00033]: 2008 c. 9.

[^f00034]: Available at https://www.theia.org/industry-policy/guidelines/statement-recommended-practice-sorp. A person unable to access the documents electronically may access them by inspection free of charge at HMRC, 100 Parliament Street, London SW1A 2BQ.

[^f00035]: 2006 c. 46.

[^f00036]: S.I. 2017/1209.

[^f00037]: “Non-reporting fund” is defined in regulation 4(2), “reportable income” in regulation 63(4), “reported income” in regulation 92(2) and “reporting fund” in regulation 50 of those Regulations.

[^f00038]: 1986 c. 41. Subsections 7B and 7C were inserted by S.I. 2013/1401.

[^f00039]: 2000 c. 8. The definition of “authorised contractual scheme” was inserted by regulation 3(6)(c)(i) of S.I. 2013/1388. Section 261D(1) (which is referred to in that definition) was inserted by regulation 3(12) of those Regulations.

[^f00040]: 1999 c. 16. Paragraph 25A was inserted by S.I. 2013/1401.

[^f00041]: 1992 c. 12. Section 99A was added by section 118(3) of the Finance Act 2004 (c. 12) and amended by S.I. 2013/1400. Section 103B was inserted by paragraph 1 of Schedule 1 to the Finance Act 2019 (c. 1). Section 103D was substituted by S.I. 2017/1204 and amended by S.I. 2019/1087. Section 103E was inserted by S.I. 2013/1400. Section 211B was inserted by S.I. 2013/1400 and amended by S.I. 2017/1204. Relevant amendments to section 212 were made by paragraph 1 of Schedule 23 to the Finance Act 1993 (c. 34), section 137 of the Finance Act 2006 (c. 25), paragraph 1 of Schedule 27 to the Finance Act 2007 (c. 11), S.I. 2009/3001, paragraph 249 of Schedule 1 to the Corporation Tax Act 2010 (c. 4), paragraph 85 of Schedule 16 of the Finance Act 2012, S.I. 2013/1400 and paragraph 56(1) of Schedule 2 to the Finance Act 2022 (c. 3). Subsection 288(8) was amended by section 118(4)(b)(i) of the Finance Act 2004, paragraph 26(1) of Schedule 12 to the Finance Act 2006, paragraph 202 of schedule 8 to the Taxation (International and Other Provisions) Act 2010 (c. 8), paragraph 148(3)(b) of Schedule 45 to the Finance Act 2013 (c. 29), S.I. 2013/1400, S.I. 2017/1204 and paragraph 87(3) of Schedule 1 to the Finance Act 2019.

[^f00042]: Schedule 5AAA was added by paragraph 21 of Schedule 1 to the Finance Act 2019 (c. 1); relevant amendments were made by S.I. 2020/315 and 2021/213.

[^f00043]: Schedule 7AC was inserted by paragraph 1 of Schedule 8 to the Finance Act 2002 (c. 23). Paragraphs 3A, 3B and 30A of Schedule 7AC were inserted by section 28 of the Finance (No. 2) Act 2017 (c. 32).

[^f00044]: S.I. 2013/2819.

[^f00045]: 2001 c. 2. Sections 262AA to 262AF were inserted by section 40 of the Finance (No. 2) Act 2017. Section 262AB was amended by S.I. 2019/1087. Section 262AEA was inserted by S.I. 2019/1087.

[^f00046]: Sections 270IC to 270IE were inserted by S.I. 2019/1087.

[^f00047]: 2003 c. 14.

[^f00048]: Section 102A was added by paragraph 1 of Schedule 16 to the Finance Act 2016 (c. 24) and amended by S.I. 2019/689.

[^f00049]: Section 118 was renumbered as s118(1) and s118(2) added by paragraph 10 of Schedule 16 to the Finance Act 2016 (c. 24).

[^f00050]: Section 122 was amended by paragraphs 5(6), 22(7) and 25(4) of Schedule 39 to the Finance Act 2004 (c. 12), paragraph 6 of Schedule 8 to the Finance Act 2005 (c. 7), paragraph 5 of Schedule 30 to the Finance Act 2008 (c. 9), S.I. 2009/56, paragraph 23 of Schedule 3 to the Scotland Act 2012 (c. 11), paragraph 8 of Schedule 39 and paragraph 7 of Schedule 40 to the Finance Act 2013 (c. 29), paragraph 12 of Schedule 1 to the Stamp Duty Land Tax Act 2015 (c. 1), paragraph 11 of Schedule 16 to the Finance Act 2016 and paragraph 4 of Schedule 16 to the Finance Act 2021 (c. 26).

[^f00051]: Schedule 4A was inserted by paragraph 4 of Schedule 35 to the Finance Act 2012 (c. 14). Paragraph 2 of Schedule 4A was amended by paragraph 12 of Schedule 16 to the Finance Act 2016, paragraph 7(2)(b) of Schedule 17 to the Finance Act 2021 and section 7(2)(a)(ii) of the Finance (No. 2) Act 2024 (c. 12).

[^f00052]: Paragraphs 7 and 15 of Schedule 9A were inserted by paragraph 5 of Schedule 16 to the Finance Act 2021.

[^f00053]: Paragraph 11 of Schedule 17A was inserted by paragraph 22(2) of Schedule 39 to the Finance Act 2004. Paragraph 11 was amended by paragraphs 7 and 12 of Schedule 10 to the Finance (No. 2) Act 2005 (c. 22), S.I. 2010/814 and paragraph 14 of Schedule 16 to the Finance Act 2016 (c. 24).

[^f00054]: Section 65A was inserted by paragraph 3 of Schedule 16 to the Finance Act 2016. Sections 77 and 77A were substituted for section 77 by the Finance Act 2008 (c. 9). Section 77 was amended by paragraph 17 of Schedule 3 to the Scotland Act 2012 (c. 11), paragraph 5 of Schedule 39 to the Finance Act 2013 (c. 29) and paragraph 9 of Schedule 1 to the Stamp Duty Land Tax Act 2015 (c. 1). Section 81 was amended by section 302(5) of, and paragraph 17(3) of Schedule 39 to, the Finance Act 2004 (c. 12), section 80(4)(b) of, and paragraph 1 of Schedule 27 to, the Finance Act 2007 (c. 11), paragraph 3 of Schedule 40 to the Finance Act 2013, paragraph 7 of Schedule 16 to the Finance Act 2016, section 46(4) of the Finance Act 2019 (c. 1), paragraph 2 of Schedule 17 and paragraph 3 of Schedule 23 to the Finance Act 2021 (c. 26) and paragraph 3 of Schedule 23 to the Finance (No. 2) Act 2023 (c. 30). Section 86 was amended by section 80(6)(a) and 80(6)(b) of the Finance Act 2007, paragraph 26 of Schedule 61 to the Finance Act 2009 (c. 10), paragraph 6 of Schedule 40 to the Finance Act 2013, paragraph 8 of Schedule 16 to the Finance Act 2016, section 46(6) of the Finance Act 2019, paragraph 5 of Schedule 17 and paragraph 6 of Schedule 23 to the Finance Act 2021 and paragraph 6 of Schedule 23 to the Finance (No. 2) Act 2023. Section 87 was amended by paragraphs 17(4)(a), 19(3) and 22(5) of Schedule 39 to the Finance Act 2004, paragraph 5 of Schedule 22 to the Finance Act 2011 (c. 11), paragraph 4 of Schedule 41 to the Finance Act 2013, paragraph 9 of Schedule 16 to the Finance Act 2016, section 46(7) of the Finance Act 2019, paragraph 6 of Schedule 17 and paragraph 7 of Schedule 23 to the Finance Act 2021 and paragraph 7 of Schedule 23 to the Finance (No. 2) Act 2023.

[^f00055]: Schedule 7A was inserted by paragraph 4 of Schedule 16 to the Finance Act 2016.

[^f00056]: Section 520 was amended by paragraph 534 of Schedule 1 to the Income Tax Act 2007 (c. 3), paragraph 469 of Schedule 1 to the Corporation Tax Act 2010, S.I. 2013/636, S.I. 2017/1182 and section 10 of the Finance (No. 2) Act 2017.

[^f00057]: Section 528 was amended by paragraph 4(3) of Schedule 4 to the Finance Act 2012 (c. 14), S.I. 2014/518, paragraph 2 of Schedule 3 to the Finance Act 2022 (c. 3) and paragraphs 2, 3 and 4 of Schedule 7 to the Finance Act 2024 (c. 3). Section 535A was inserted by paragraph 115 of Schedule 1 to the Finance Act 2019 (c. 1) and amended by paragraph 9 of Schedule 7 to the Finance Act 2024.

[^f00058]: S.I. 2017/1209.

Reading this document does not replace reading the official text published on legislation.gov.uk. Contains public sector information licensed under the Open Government Licence v3.0. We assume no responsibility for any inaccuracies arising from the conversion of the original CLML XML to this format.

This text is published under legislation.gov.uk's own terms of reuse, not a Legalize or public-domain licence. legislation.gov.uk
Open Government Licence v3.0 (attribution required)
© Crown and database right. Derived from content available under the Open Government Licence v3.0 from legislation.gov.uk.