Suzi Edwards, senior manager in the Deloitte Stamp Tax Consultancy, examines the potential success of the proposed UK contractual fund against its European competitors for UK stamp tax purposes.
The UK offers two UCITS-compliant vehicles, the authorised unit trust (AUT) and open-ended investment company (OEIC). However, neither provides investors nor fund managers with a complete UK tax solution. Other European member states offer a different vehicle, the contractual fund, providing a highly tax-efficient and flexible investment product. Luxembourg Fonds Commun de Placements (FCPs) and Irish Common Contractual Funds are the two current contractual funds of choice. For stamp tax, a contractual fund like an FCP is probably the most efficient pooling vehicle in the market. I...
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