The Co-ownership Contractual Schemes (Tax) Regulations 2025
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59 Seeding relief: amendments to Schedule 7A
(1) Schedule 7A to FA 2003 (PAIF seeding relief and COACS seeding relief) is amended as follows. (2) For the heading of the Schedule substitute “Seeding relief”. (3) In the heading to Part 2 of the Schedule omit “authorised”. (4) In the italic heading before paragraph 10 for “COACS” substitute “Co-ownership scheme”. (5) In paragraph 10— (a) in sub-paragraph (1) for “COACS” substitute “co-ownership scheme”, (b) in sub-paragraph (2) omit “authorised”, (c) in sub-paragraph (4) omit “authorised”, and (d) after sub-paragraph (5) insert— (5A) But condition D is met in a case where the purchaser is a Reserved Investor Fund (Contractual Scheme) only if an entry notice has been given in relation to the scheme on or before the effective date. (5B) In sub-paragraph (5A), “entry notice” has the meaning it has in the Co-ownership Contractual Schemes (Tax) Regulations 2025. . (6) In paragraph 11— (a) in sub-paragraph (1)(a) omit “authorised”, (b) in sub-paragraph (2) omit “authorised”, and (c) in sub-paragraph (3)(a) for “COACS” substitute “co-ownership scheme”. (7) In paragraph 12— (a) in sub-paragraph (1) for “COACS” substitute “co-ownership scheme”, (b) in sub-paragraph (2)— (i) for “COACS” substitute “Co-ownership scheme”, and (ii) omit “authorised”, (c) in sub-paragraph (3)— (i) for “COACS” substitute “Co-ownership scheme”, and (ii) omit “authorised”, and (d) in sub-paragraph (4) for “COACS” substitute “Co-ownership scheme”. (8) In the italic heading before paragraph 13 omit “authorised”. (9) In paragraph 13— (a) in sub-paragraph (1)— (i) for “COACS” substitute “co-ownership scheme”, and (ii) omit “authorised”, (b) in sub-paragraph (2) omit “authorised”, (c) in sub-paragraph (3) for “COACS” substitute “co-ownership scheme”, and (d) in sub-paragraph (4) omit “authorised”. (10) In the italic heading before paragraph 14, after “met” insert “by COACS”. (11) In paragraph 14— (a) before sub-paragraph (1) insert— (A1) This paragraph applies where co-ownership scheme seeding relief has been allowed in respect of a transaction (“the relevant transaction”) entered into by— (a) a co-ownership authorised contractual scheme, or (b) a Reserved Investor Fund (Contractual Scheme) that has since become a co-ownership authorised contractual scheme. , (b) in sub-paragraph (1) in the words before paragraph (a), for the words from “COACS” to “and” substitute “, in relation to the relevant transaction,”, and (c) in sub-paragraph (3), for “COACS” substitute “co-ownership scheme”. (12) In paragraph 15— (a) after sub-paragraph (1) insert— (1A) Sub-paragraphs (2) to (8) and (9) apply where the relevant transaction was entered into by a co-ownership authorised contractual scheme. (1B) Sub-paragraph (8A) applies where the relevant transaction was entered into by a Reserved Investor Fund (Contractual Scheme) that has since become a co-ownership authorised contractual scheme. , and (b) after sub-paragraph (8) insert— (8A) A co-ownership authorised contractual scheme which at the time of the relevant transaction was a Reserved Investor Fund (Contractual Scheme) meets the genuine diversity of ownership condition at any time that the scheme— (a) meets the genuine diversity of ownership condition under regulation 7 of the Co-ownership Contractual Schemes (Tax) Regulations 2025 (but not solely by virtue of regulation 9 of those Regulations), or (b) meets the non-close condition under regulation 8 of those Regulations (but not solely by virtue of regulation 9 of those Regulations). . (13) In paragraph 16— (a) in sub-paragraphs (1), (2) and (3) for “COACS” in each place it occurs substitute “co-ownership scheme”, (b) in sub-paragraph (4) omit “authorised”, (c) in sub-paragraph (5) for “COACS” substitute “co-ownership scheme”, and (d) in sub-paragraph (10) for “COACS” substitute “co-ownership scheme”. (14) In paragraph 17— (a) in sub-paragraph (1)(a) omit “authorised”, (b) in sub-paragraph (2)(a) for “COACS” substitute “co-ownership scheme”, (c) in sub-paragraph (5) in the definition of “SDLT” for “COACS” substitute “co-ownership scheme”, and (d) in sub-paragraph (6)— (i) in the definition of “relevant seeding transaction” omit “authorised”, (ii) in the definition of “seeding transaction” for “COACS” substitute “co-ownership scheme”, and (iii) in the definition of “the value of V’s investment in the scheme” omit “authorised”. (15) In paragraph 18— (a) in sub-paragraph (1)(a) for “COACS” substitute “co-ownership scheme”, (b) in sub-paragraph (3) omit “authorised”, and (c) in sub-paragraph (5) for “COACS” substitute “co-ownership scheme”. (16) In paragraph 19(1) and (4) omit “authorised”. (17) In paragraph 20— (a) in each place it occurs, omit “authorised”, and (b) in paragraph (a) of the definition of “units in the co-ownership authorised contractual scheme”, for “COACS” substitute “scheme”. (18) In paragraph 21— (a) for ““COACS seeding relief”” substitute ““co-ownership scheme seeding relief””, (b) in the definition of “co-ownership authorised contractual scheme”, after “(2),” insert “(2A),”, and (c) in the definitions of “non-qualifying individual”, “operator”, “portfolio test”, “relevant disposal” and “seeding period” omit “authorised”.
59 Seeding relief: amendments to Schedule 7A
(1) Schedule 7A to FA 2003 (PAIF seeding relief and COACS seeding relief) is amended as follows. (2) For the heading of the Schedule substitute “Seeding relief”. (3) In the heading to Part 2 of the Schedule omit “authorised”. (4) In the italic heading before paragraph 10 for “COACS” substitute “Co-ownership scheme”. (5) In paragraph 10— (a) in sub-paragraph (1) for “COACS” substitute “co-ownership scheme”, (b) in sub-paragraph (2) omit “authorised”, (c) in sub-paragraph (4) omit “authorised”, and (d) after sub-paragraph (5) insert— (5A) But condition D is met in a case where the purchaser is a Reserved Investor Fund (Contractual Scheme) only if an entry notice has been given in relation to the scheme on or before the effective date. (5B) In sub-paragraph (5A), “entry notice” has the meaning it has in the Co-ownership Contractual Schemes (Tax) Regulations 2025. . (6) In paragraph 11— (a) in sub-paragraph (1)(a) omit “authorised”, (b) in sub-paragraph (2) omit “authorised”, and (c) in sub-paragraph (3)(a) for “COACS” substitute “co-ownership scheme”. (7) In paragraph 12— (a) in sub-paragraph (1) for “COACS” substitute “co-ownership scheme”, (b) in sub-paragraph (2)— (i) for “COACS” substitute “Co-ownership scheme”, and (ii) omit “authorised”, (c) in sub-paragraph (3)— (i) for “COACS” substitute “Co-ownership scheme”, and (ii) omit “authorised”, and (d) in sub-paragraph (4) for “COACS” substitute “Co-ownership scheme”. (8) In the italic heading before paragraph 13 omit “authorised”. (9) In paragraph 13— (a) in sub-paragraph (1)— (i) for “COACS” substitute “co-ownership scheme”, and (ii) omit “authorised”, (b) in sub-paragraph (2) omit “authorised”, (c) in sub-paragraph (3) for “COACS” substitute “co-ownership scheme”, and (d) in sub-paragraph (4) omit “authorised”. (10) In the italic heading before paragraph 14, after “met” insert “by COACS”. (11) In paragraph 14— (a) before sub-paragraph (1) insert— (A1) This paragraph applies where co-ownership scheme seeding relief has been allowed in respect of a transaction (“the relevant transaction”) entered into by— (a) a co-ownership authorised contractual scheme, or (b) a Reserved Investor Fund (Contractual Scheme) that has since become a co-ownership authorised contractual scheme. , (b) in sub-paragraph (1) in the words before paragraph (a), for the words from “COACS” to “and” substitute “, in relation to the relevant transaction,”, and (c) in sub-paragraph (3), for “COACS” substitute “co-ownership scheme”. (12) In paragraph 15— (a) after sub-paragraph (1) insert— (1A) Sub-paragraphs (2) to (8) and (9) apply where the relevant transaction was entered into by a co-ownership authorised contractual scheme. (1B) Sub-paragraph (8A) applies where the relevant transaction was entered into by a Reserved Investor Fund (Contractual Scheme) that has since become a co-ownership authorised contractual scheme. , and (b) after sub-paragraph (8) insert— (8A) A co-ownership authorised contractual scheme which at the time of the relevant transaction was a Reserved Investor Fund (Contractual Scheme) meets the genuine diversity of ownership condition at any time that the scheme— (a) meets the genuine diversity of ownership condition under regulation 7 of the Co-ownership Contractual Schemes (Tax) Regulations 2025 (but not solely by virtue of regulation 9 of those Regulations), or (b) meets the non-close condition under regulation 8 of those Regulations (but not solely by virtue of regulation 9 of those Regulations). . (13) In paragraph 16— (a) in sub-paragraphs (1), (2) and (3) for “COACS” in each place it occurs substitute “co-ownership scheme”, (b) in sub-paragraph (4) omit “authorised”, (c) in sub-paragraph (5) for “COACS” substitute “co-ownership scheme”, and (d) in sub-paragraph (10) for “COACS” substitute “co-ownership scheme”. (14) In paragraph 17— (a) in sub-paragraph (1)(a) omit “authorised”, (b) in sub-paragraph (2)(a) for “COACS” substitute “co-ownership scheme”, (c) in sub-paragraph (5) in the definition of “SDLT” for “COACS” substitute “co-ownership scheme”, and (d) in sub-paragraph (6)— (i) in the definition of “relevant seeding transaction” omit “authorised”, (ii) in the definition of “seeding transaction” for “COACS” substitute “co-ownership scheme”, and (iii) in the definition of “the value of V’s investment in the scheme” omit “authorised”. (15) In paragraph 18— (a) in sub-paragraph (1)(a) for “COACS” substitute “co-ownership scheme”, (b) in sub-paragraph (3) omit “authorised”, and (c) in sub-paragraph (5) for “COACS” substitute “co-ownership scheme”. (16) In paragraph 19(1) and (4) omit “authorised”. (17) In paragraph 20— (a) in each place it occurs, omit “authorised”, and (b) in paragraph (a) of the definition of “units in the co-ownership authorised contractual scheme”, for “COACS” substitute “scheme”. (18) In paragraph 21— (a) for ““COACS seeding relief”” substitute ““co-ownership scheme seeding relief””, (b) in the definition of “co-ownership authorised contractual scheme”, after “(2),” insert “(2A),”, and (c) in the definitions of “non-qualifying individual”, “operator”, “portfolio test”, “relevant disposal” and “seeding period” omit “authorised”.
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