Five years after the launch of the first UK authorised contractual scheme (ACS) – also known as the UK tax transparent fund (UK TTF) – in 2014, there are 22 UK TTFs in the market, with 172 sub-funds amounting to billions of assets under management. Mariano Giralt, Christopher Mitchell and Gildine Cassou look at the scheme’s impact.
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Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default