IFM18000 - Investment transactions 바카라 사이트“ the 바카라 사이트˜investment transactions list바카라 사이트™

Introduction

Investment funds carry out investment transactions to generate returns for investors. This may be in line with regulatory requirements such as those which apply to authorised investment funds.

UK tax law differentiates between trading and investing. The meaning of trading is discussed in the Business Income Manual from BIM20000. In practice the standard tests did not easily apply in the context of the transactions carried out by investment funds. From 1 September 2009 the position was therefore clarified for authorised investment funds by the introduction of a list of 바카라 사이트˜investment transactions바카라 사이트™. Subject to other conditions being satisfied, profits on such transactions are not taxable as trade profits.

The list of investment transactions - known as the 'investment transactions list' - is now set out in regulation 2 of the Investment Transactions (Tax) Regulations 2014 (SI 2014/685). The following guidance sets out the list of investment transactions and the types of funds which may rely on it.

Where a fund carries out transactions not on the investment transactions list or is not eligible to rely on the investment transactions list, any question as to whether the fund is investing or trading has to be considered by reference to the normal rules and based on the facts of each case.

Applicable funds

The following funds may rely on the 바카라 사이트˜investment transactions list바카라 사이트™:

  • Diversely owned authorised investment funds (AIFs) - see IFM02260.
  • Exempt unauthorised unit trusts (EUUTs) 바카라 사이트“ see IFM10240.
  • Diversely owned reporting offshore funds - see IFM12558.
  • Approved investment trusts - see IFM14268.

Investment transactions

바카라 사이트œInvestment transactions바카라 사이트 is defined in regulation 2 of SI 2014/685:

(a) any transaction in stocks and shares,

(b) any transaction in a relevant contract (as defined in regulation 3),

(c) any transaction which results in a fund becoming a party to a loan relationship or a related transaction in respect of a loan relationship (as defined in regulation 4),

(d) any transaction in units in a collective investment scheme (those terms are defined in regulation 5),

(e) any transaction in securities of any description not falling within paragraphs (a) to (d),

(f) any transaction consisting in the buying or selling of any foreign currency,

(g) any transaction in a carbon emission trading product (as defined in regulation 6), and

(h) any transaction in rights under a life insurance policy.

The Investment Manager (Investment Transactions) (Cryptoassets) Regulations 2022 added 바카라 사이트œdesignated cryptoassets바카라 사이트 to the investment transaction list for the purposes of the Investment Manager Exemption (see INTM269079A). However, this is only relevant to the Investment Manager Exemption. Designated cryptoassets are not included in the list contained in regulation 2 of SI 2014/685.