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ARTICLE · 18 NOVEMBER 2024

RIF To Be Introduced By April 2025

Gowling WLG
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The UK's new Reserved Investor Fund (RIF) aims to enhance tax-efficient investment vehicles domestically, with expected benefits like CGT exemption and reduced SDLT. However, stringent compliance risks may hinder adoption without more flexible regulations.

CanadaTax
Paul Shaw
Paul Shaw
Matthew Poole
Matthew Poole
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1. Introduction of RIF confirmed

The 2024 Autumn Budget included confirmation that the Reserved Investor Fund (Contractual Scheme) ("RIF") will be introduced by April 2025.

The previous Government had already brought forward enabling legislation for the RIF in Finance (No 2) Act 2024 and released draft regulations for consultation in March 2024 ("Draft RIF Regs"). Those regulations provided helpful clarifications in respect of certain aspects of the tax treatment of the RIF but included a number of areas that industry considered problematic.

We expect updated regulations to soon be released by the new Government ("Updated RIF Regs") and hope they will take on board feedback previously provided by industry. This article seeks to draw out the key aspects of the Draft RIF Regs and sets out the key changes that we would like to see in the Updated RIF Regs when released.

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