Corporation Tax Act 2010 section 617

Authorised unit trust treated as UK resident company

Section 617 establishes that, for tax purposes, an authorised unit trust is treated as though it were a UK resident company, with unit holders' rights treated as shares in that company.

• For income arising to the trustees of an authorised unit trust, the tax legislation treats the trustees as if they were a UK resident company and the unit holders' rights as if they were shares in that company.
• References to a body corporate in the Corporation Tax Acts are read in line with this treatment, and the rules requiring companies to provide tax certificates (sections 1104 to 1107) apply with any necessary modifications.
• Treating unit holders' rights as shares does not prevent the trust from making interest distributions to unit holders, which remain governed by their own specific rules.
• The detailed taxation rules for both the authorised unit trust itself and its unit holders are set out in the Authorised Investment Funds (Tax) Regulations 2006 (SI 2006/964), with the term "interest distribution" defined in regulation 18(3) of those regulations.