UK Property Rich Collective Investment Funds
On 4th November 2020 HMRC released a further consultation on new draft regulations in respect to the taxation of UK Property Rich Collective Investment Vehicles. If this legislation is enacted (as drafted) then overseas Insurers, such as Utmost, holding such funds will not be subject to corporation tax providing their holdings in such funds via their long term business funds do not exceed a specified threshold. The draft regulations apply retrospectively to any disposals on or after 6 April 2019. The regulations have been widely praised by industry and reflect the lobbying by representatives of the Manx Insurance Association (MIA) and the Association of International Life Offices (AILO).
Due to the release of this draft legislation the Utmost group of companies will immediately suspend any future forced sales of UK Property Rich Collective Investment Vehicles in the open architecture fund range pending the outcome of the consultation. However, sales of UK Property Rich funds in the guided architecture fund range will proceed as previously communicated.
Please be aware that, as this draft legislation has not currently been enacted, policyholders will not be able to link their open architecture policies to investments in UK Property Rich Funds until the outcome of the consultation is known.