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Tax transparent fund : ウィキペディア英語版
Tax transparent fund
A Tax Transparent Fund (TTF) is the proposed authorised collective investment scheme structure in the United Kingdom once the UK Finance Bill 2012 becomes an act and when the Financial Services and Markets Act 2000 and the Corporation Tax Act 2010 are amended, sometime mid-2012.〔Gary Jackson, (''Finance Bill 2012 confirms tax transparent fund details'' ), Fundweb.co.uk, 6 December 2011. Retrieved 2012-01-26.〕〔Natalie Kenway, (''Tax-transparent funds set for 2012 rollout'' ), Investment Week, 10 June 2011. Retrieved 2012-01-26.〕
TTF’s will then have the option to be based in the UK rather than in competing European domiciles.
Both Luxembourg and Ireland have already introduced such structures, formally known as the Fond commun de placement (FCP) and the Common contractual fund (CCF).
== History ==

*In 2010 a lobby formed for a U.K. transparent fund to be developed ahead of the implementation of the Undertakings for Collective Investment in Transferable Securities Directives (UCITS) IV directive in July 2011. It was felt that a transparent fund would be a beneficial vehicle to complement the existing range of UK funds. Feeder fund investors under a master/feeder structure would benefit from tax treaty agreements, whilst fund managers could access greater economies of scale when all the assets are pooled in a tax efficient manner.
*In the UK Government’s budget of March 2011, an announcement heralded a positive step forward in bringing a TTF to the industry by the summer of 2012.〔
*In May 2011 an indication was given that regulation rather than legislation was required, and it would allow for more time to consult on the issues.
*From May – December 2011〔http://www.hmrc.gov.uk/tiin/tiin662.pdf〕 there was an informal consultation process with industry, advisers, HM Treasury, HMRC and Financial Services Authority convening working groups, with experts from a commercial, product, legal and tax perspective.
*In December 2011 an initial draft of the Finance Bill 2012 confirmed that regulators will be granted powers to exempt qualifying funds from stamp duty and stamp duty reserve tax. Subsequently the Corporation Tax Act 2010 requires amendment to ensure that the new TTF funds are not accountable to pay for corporation tax. Overall this requires an amendment to the Financial Services and Markets Act 2000 to ensure all boundaries are set and any legalities are pre-determined before TTF’s are launched.
*In January 2012 a consultation document was published. The government aims to have the new/amended legislation and the TTF vehicle to come into effect by the summer of 2011.

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