Authorised contractual schemes: reducing tax complexity for investors

Authorised contractual schemes: reducing tax complexity

The consultation covers capital allowances for ACS investors and new reporting requirements.

Also on

On 9 August 2016 HMRC published a consultation paper on authorised contractual schemes (ACS). This covers two matters: the application of the capital allowances regime to ACS investors (this will only be relevant when the ACS holds real estate and the unitholders are not tax-exempt); and new reporting requirements (modelled on the existing requirements for offshore funds).

There is little detail provided in the capital allowances section but the consultation is a positive step as the tax transparent nature of the ACS can make operation of capital allowances elections difficult in practice.

The new reporting requirements were not expected. The ACS remains transparent but HMRC are considering making it a requirement to:

  • provide appropriate reports to investors; 
  • provide such reports to HMRC; and 
  • provide information to HMRC on investors. 

Given that ACS are held by insurers and pension schemes the benefit of introducing these extra compliance measures is not entirely clear.

There are additional ways in which the ACS legislation could be clarified, particularly in relation to loan relationships. The consultation does not mention these but we intend to raise them during the consultation process.

To read the consultation document, click here.

Please contact us if you have any comments you would like us to raise with HRMC as part of the process.


For further information please contact :

Nathan Hall

Gordon Gray 

Tax Matters Digest

View KPMG's weekly newsletter covering the latest issues in taxation and government announcements relating to tax matters.

Read more

Connect with us


Request for proposal



KPMG’s new-look website

KPMG has launched a state of the art digital platform that enhances your experience and provides improved access to our content and our people, whatever device you are on.