SDLTM09945 - SDLT - increased rates for non-resident transactions: Co-ownership authorised contractual schemes - para 15 Sch 9A FA03
General guidance on co-ownership authorised contractual schemes (CoACSs) can be found at IFM08000 onwards.
A CoACS is a form of collective investment scheme. It is essentially a pool of assets held by a depositary and managed on behalf of a number of investors in accordance with contractual arrangements agreed between the parties. For SDLT purposes, a CoACS is treated as a company, and the rights of investors are shares in the company.
With one exception, a CoACS is UK resident for the purposes of the surcharge (paragraph 15(1)).
»Ê¹ÚÌåÓýapp exception to this rule is that certain collective investment schemes which are treated as CoACSs under section 102A of FA 2003 (EEA equivalent schemes) are non-resident for the purposes of the surcharge (paragraph 15(2)).
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