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An elective regime is to be introduced for UK AIFs that will move the point of taxation from the fund to the investor so that the investor is treated as though he had invested in the underlying assets directly.
The new regime will have effect on and after 1 September 2009.
Currently UK AIFs are normally chargeable to corporation tax on taxable income at a special rate of 20%.
That will remain the case under the new regime but UK AIFs that meet certain conditions will be able to elect to be treated as a tax elected fund.
Such funds will be required to make two types of distribution of the income they receive: a dividend and a non dividend (interest) distribution.
UK dividend income will remain non taxable in the fund and will be distributed as a dividend. For all other income that is distributed as...
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