Asset Holding Companies (AHCs)

Overview:

HM Treasury and HM Revenue & Customs are considering the introduction of a tax regime for UK-based Asset Holding Companies (AHCs) within broader collective investment structures.  Two consultations on this matter have been conducted.  AIMA and the ACC remain in contact with HMT and HMRC to ensure the vehicle is conceptualised most optimally. 

Current work: 

The ACC and AIMA have provided comments to support HM Treasury’s consideration of this new regime.  In our response, the ACC and AIMA emphasised that the AHC regime would be attractive to many alternative investment managers if the vehicle meets the following interlinked criteria:

  • Preserve the principle of tax neutrality for underlying investors in private investment funds;
  • Be simple for funds, managers, and investors to access the regime;
  • Align wherever possible with existing practices and processes;
  • Be competitive with existing AHC structuring options available to alternative investment managers in Luxembourg and Ireland but idealy represent an advance on these; and
  • Be compatible with developing OECD standards.

Previously, the ACC, AIMA and the Managed Funds Association (MFA) submitted a joint response  to the first stage consultation on the role of Asset Holding Companies (AHC) as part of the broader review of the UK funds regime. 

Upcoming actions: 

HMT and HMRC are considering consultation responses with a view to release an initial tranche of draft legislation in July 2021 and a second tranche in Autumn 2021. 

(Last updated: 29 June 2021)