On 24 May 2012, HMRC announced consultation on proposed changes to the tax rules governing unauthorised unit trusts (UUTs). In broad terms, a UUT is a collective investment scheme that is not authorised by the Financial Services Authority. Different tax regimes apply as between authorised investment funds and unauthorised unit trusts. UUTs generally fall under the income tax regime. In the case of authorised investment funds, where the fund is an open-ended investment company, the corporation tax regime applies (with modifications). Where the fund is an authorised unit trust, the trustees thereof are similarly brought within the charge to corporation...