The Co-ownership Contractual Schemes (Tax) Regulations 2025

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1. Introductory Text

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   Part 1 Preliminary matters

   1. 1. Citation and commencement

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   Part 2 Reserved Investor Fund (Contractual Schemes): general

   1. Chapter 1 Interpretation

      1. 2. Interpretation: Part 2

   2. Chapter 2 Becoming a RIF

      1. 3. Timing: becoming a RIF

      2. 4. Entry notices: general

   3. Chapter 3 Qualifying conditions

      1. 5. Qualifying conditions

      2. 6. A UK-based scheme

      3. 7. Genuine diversity of ownership condition

      4. 8. Non-close condition

      5. 9. Ownership requirement treated as met for initial period

      6. 10. Restriction requirement

      7. 11. Non-UK property assets condition

      8. 12. UK property rich condition

      9. 13. UK property rich condition treated as met for initial period

      10. 14. Exempt investor condition

   4. Chapter 4 Changes in qualifying conditions and breaches of qualifying conditions

      1. 15. Change in restriction conditions met

      2. 16. Breach of ownership requirement: opportunity to rectify etc

      3. 17. Multiple breaches of ownership requirement within 12 month period

      4. 18. Breach of restriction requirement: opportunity to rectify etc

      5. 19. Winding up of a RIF that is UK property rich

   5. Chapter 5 Ceasing to be a RIF

      1. 20. Causes and timing

      2. 21. Breach of qualifying conditions: requirement to notify HMRC

      3. 22. Exit notices

      4. 23. Relevant declarations in entry notice

      5. 24. Cessation notice

      6. 25. Ceasing to be a RIF: deemed disposal of units

      7. 26. Gains accruing on deemed disposals

   6. Chapter 6 SDLT consequences of becoming and ceasing to be a RIF

      1. 27. Interpretation of this Chapter

      2. 28. Land transaction upon unauthorised contractual scheme becoming a RIF

      3. 29. Application of Part 4 of FA 2003 to a RIF that ceases to be a RIF and becomes an eligible co-ownership scheme

      4. 30. Land transaction upon RIF or eligible co-ownership scheme becoming unauthorised contractual scheme

      5. 31. Withdrawal of seeding relief: application to postpone payment of tax where appeal against relevant decisions

      6. 32. Determination of application under regulation 31 and referral to tribunal

   7. Chapter 7 Accounts

      1. 33. Beginning and end of accounting period

      2. 34. Preparation of accounts

   8. Chapter 8 Information requirements

      1. 35. Information to be provided to participants

      2. 36. Information to be provided to other RIF or authorised co-ownership scheme

      3. 37. Information to be provided to HMRC

      4. 38. Further information to be provided to HMRC

   9. Chapter 9 Further provision about notices, information and applications

      1. 39. Further provision about notices, information and applications

   10. Chapter 10 Penalties for failure to give information or notice

       1. 40. Penalties for failure to give information or notice

   11. Chapter 11 Umbrella schemes: modification of this Part

       1. 41. Umbrella schemes: general

       2. 42. Umbrella schemes: restriction requirement

       3. 43. Umbrella schemes: becoming a Reserved Investor Fund (Contractual Scheme)

       4. 44. Umbrella schemes: ceasing to be a Reserved Investor Fund (Contractual Scheme)

       5. 45. Umbrella schemes: additional notification requirements

   12. Chapter 12 Investment in offshore funds

       1. 46. Interpretation: Chapter 12

       2. 47. Investments in reporting offshore funds

       3. 48. Investments in non-reporting offshore funds: first case

       4. 49. Investments in non-reporting offshore funds: second case

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   Part 3 Co-ownership contractual schemes: amendments to relevant legislation

   1. Chapter 1 Finance Act 1986 and Finance Act 1999

      1. 50. Stamp duty reserve tax: exceptions

      2. 51. Stamp duty: exemptions

   2. Chapter 2 Taxation of Chargeable Gains Act 1992

      1. 52. Collective investment schemes

      2. 53. Property rich collective investment vehicles

      3. 54. Exemptions for disposals by companies with substantial shareholding

   3. Chapter 3 Capital Allowances Act 2001

      1. 55. Plant and machinery allowances

      2. 56. Structures and building allowances

   4. Chapter 4 Finance Act 2003

      1. 57. Stamp duty land tax: contractual schemes

      2. 58. Stamp duty land tax: seeding relief

      3. 59. Seeding relief: amendments to Schedule 7A

   5. Chapter 5 Income Tax (Trading and Other Income) Act 2005

      1. 60. Personal portfolio bonds: the property categories

   6. Chapter 6 Corporation Tax Act 2010

      1. 61. Real Estate Investment Trusts

   7. Chapter 7 The Co-ownership Authorised Contractual Schemes (Tax) Regulations 2017

      1. 62. Amendment of The Co-ownership Authorised Contractual Schemes (Tax) Regulations 2017

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   Part 4 Transitional provision

   1. 63. Application to authorised co-ownership schemes

6. Signature

7. Explanatory Note