Corporation Tax Act 2010 section 357XC

Investment management

Section 357XC excludes trades involving the management of collective investment funds from the Northern Ireland corporation tax regime.

  • A trade that consists of or includes portfolio management or risk management of collective investment funds is classified as an excluded trade
  • This covers funds known as UCITS (Undertakings for Collective Investment in Transferable Securities), as defined in EU Directive 2009/65/EC
  • It also covers Alternative Investment Funds (AIFs), as defined in the Alternative Investment Fund Managers Regulations 2013
  • The AIF category will normally cover investment trust companies, which in any event do not usually carry on a trade

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