Eversheds has advised Royal London Asset Management (RLAM) on the conversion to its property fund to the new, more tax-efficient Property Authorised Investment Fund (PAIF) status.
RLAM’s flagship £188m Royal London Exempt Property Unit Trust has become a PAIF – the open-ended fund equivalent of a REIT that gives investors access to a wider pool of assets and allows for investment in vehicles such as exchange traded funds and other collective investment products.
On this transaction Eversheds partner and financial services head Pamela Thompson led a team composed of funds, tax and real estate specialists who advised on the structuring of the transaction, the establishment of the PAIF and its feeder fund and the conversion process, dealing with a number of regulatory and tax hurdles to achieve this.
Thompson said: “I think we’ll see [the creation of more PAIFs] in the coming months, I think there’s an appetite for this. But it’ll be fairly slow because we still need clarity and understanding on the regulatory issues, people are still working on regulations to make them areas that can function properly.”
PAIFs were first introduced in 2008 in a bid to provide the UK with a more tax-efficient open-ended authorised property fund suitable for all types of investor, from institutional to retail, tax-paying to tax-exempt. In contrast to existing UK property funds, PAIFs are not subject to corporation tax and as a result tax-exempt investors are not discouraged from backing them.
Eversheds has worked with RLAM for some time doing its authorised fund work. Partner Julian Brown is the client relationship partner.
Eversheds tax associate Camilla Spielman has also been involved in advice to HM Treasury on regulatory changes concerning the establishment of PAIFs and the firm is working with unauthorised exempt unit trusts on further future PAIF transactions.
Dundas & Wilson provided Scottish property advice.