{
  "url": "https://openlegislation.uk/authorised-investment-funds-tax-amendment-regulations-2012/note",
  "json_url": "https://openlegislation.uk/authorised-investment-funds-tax-amendment-regulations-2012/note.json",
  "legislation": "uksi/2012/519",
  "legislation_title": "The Authorised Investment Funds (Tax) (Amendment) Regulations 2012",
  "legislation_url": "https://openlegislation.uk/authorised-investment-funds-tax-amendment-regulations-2012",
  "path": "note",
  "kind": "note",
  "number": null,
  "heading": "Explanatory note",
  "text": "(This note is not part of the Regulations)\nThese Regulations amend the Authorised Investment Funds (Tax) Regulations 2006 (S.I. 2006/964) (“the principal Regulations”).\nRegulation 1 provides for citation, commencement and effect. Regulation 2 introduces the amendments to the principal Regulations.\nRegulation 3 amends regulation 13 (treatment of interest distributions for purposes of loan relationships) to prevent an interest distribution being treated as interest under a loan relationship to the extent it is not derived from taxable income.\nRegulation 4 makes a consequential amendment to regulation 22 (dividend distribution: general).\nRegulation 5 amends regulation 48 (general) to prevent the use of arrangements which artificially increase the tax treated as deducted from dividend distributions.\nRegulation 6 amends regulation 49 (calculation of unfranked part of dividend distribution) to amend the calculation of the unfranked part of a dividend distribution.\nRegulation 7 makes a consequential amendment to regulation 93 (general).\nRegulation 8 inserts regulation 96A which modifies section 490 of the Corporation Tax Act 2009 (holdings in OEICs, unit trusts and offshore funds treated as creditor relationship rights) so that dividend distributions and interest distributions will be brought into account under Part 5 of that Act (loan relationships) by an investor in an authorised investment fund to which that section applies.\nRegulation 9 amends the Authorised Investment Funds (Tax) (Amendment No. 3) Regulations 2008 to omit the transitory provision which treats certain schemes authorised before 1st January 2009 as meeting the genuine diversity of ownership condition in regulation 14C of the principal Regulations.\nA Tax Information and Impact Note covering this instrument will be published on the HMRC website at http://www.hmrc.gov.uk/thelibrary/tiins.htm.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2012/519/note",
    "retrieved_at": "2026-10-29T01:40:13.246285+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}