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Taxation of Collective Investment Institutions

We inform you about the consequences of BREXIT on the taxation of Collective Investment Schemes.

Article 53 regulates the taxation of members or unit-holders of Collective Investment Undertakings, providing in paragraph 2 that the taxation of members or unit-holders of CIIs incorporated or domiciled in a Member State of the EU and registered in a special register of the CNMV will occur when the units are transferred or dividends are distributed.

It follows from this provision that the income attribution system does not apply to such income.

From 1 January 2021 the non-applicability of Article 53.2 of the LIS to CIS incorporated in the UK and registered with the CNMV for marketing means that a case-by-case analysis must be carried out to determine the taxation of this income.