SAVINGS AND INVESTMENTS

ISA Limits
Individual Savings Account (ISA) limits of £7,000 maximum and £3,000 for cash will be retained until 5 April 2010.

(They had been due to fall from 6 April 2006.)

 

ISAs and Child Trust Funds
The Government will extend the rules for qualifying investments in Individual Savings Accounts (ISAs) and Child Trust Funds (CTFs), allowing the holders of such accounts and funds to invest in all retail collective investment schemes authorised by the Financial Services Authority (FSA).

The extension will take effect from 6 April 2006. It will cover authorised schemes which qualify as ‘UCITS’ schemes under the European Directive on Undertakings for Collective Investment in Transferable Securities (‘the UCITS Directive’), and ‘non-UCITS’ retail schemes, which have slightly more relaxed rules, allowing access to a wider range of investment products including real property.

However, the schemes must not restrict savers’ ability to access their savings and schemes which apply the FSA’s ‘limited redemption’ rule will not be eligible.

 

Pensions Tax Simplification
Legislation introducing an extensive and universal new regime for personal and occupational pensions was introduced in Finance Act 2004 and is due to come into force on 6 April 2006. A number of further measures will now be added, most of them covered in an Inland Revenue Technical Note published on 16 February 2005, to provide additional flexibility for pension schemes and contributors, to clarify aspects of the new rules, to smooth the transition from current to new regime and to introduce further anti-avoidance and compliance rules. Pre-existing schemes will now have at least until 6 April 2011 to modify their scheme rules.

 

Collective Investment Schemes
There will be changes to the taxation of collective investment schemes (including authorised unit trusts and authorised open-ended investment companies).
The tax arrangements for authorised trusts that issue multiple classes of units will be clarified. There will be ‘non-discrimination rules’ similar to those that already exist for open-ended investment companies.

The Finance Bill will include powers to change the relevant regulations in order to counter avoidance; to respond to future Financial Services Authority changes; to change the existing distribution rules; and to permit different tax treatment to be applied to different unit/share holders in funds that are ‘qualified investor schemes’. The Revenue will ‘consider the case for a purposive anti-avoidance test’ for qualified investor schemes. Where an investor owns a substantial portion of a qualified investor scheme, any annual increase in the value of their units/shares will be chargeable as income under self-assessment. Gains that are unrealised at the time the rule starts will be held over and treated as chargeable gains when the units are sold.

The rules determining who can receive interest distributions gross will be aligned with the gross payment rules for bank interest. However, this will not affect the deductibility of such distributions when calculating the income of an authorised investment fund chargeable to corporation tax.

Regulations will be drafted to deal with the tax treatment of authorised investment funds that own property, once the government has ‘finalised its position’ with regard to UK real estate investment trusts.

There are several other minor changes to the relevant provisions.

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