The UK Government published the final Co-ownership Contractual Schemes (Tax) Regulations 2025 on 25 February 2025, introducing the Reserved Investor Fund (RIF), effective from 19 March 2025. The RIF is an unauthorised contractual scheme designed for professional and institutional investors, with a primary focus on UK real estate but capable of holding a variety of assets.
A qualifying RIF is tax-transparent for income, meaning unit holders are taxed directly, while capital gains tax applies only upon disposal of units.
To qualify, a RIF must be UK-based, meet ownership diversity or non-close conditions, and satisfy one of three restriction requirements related to property investments or exempt investors. A 12-month grace period is available for new RIFs to meet these conditions.
The regulations set out compliance, reporting, and breach remedies, and confirm Stamp Duty Land Tax seeding relief for eligible UK property. The RIF is the UK’s first new collective investment scheme in years and complements regimes like the Qualified Asset Holding Company (QAHC).
