- Published date:
- 21 September 2026
On 10 September 2026, RE:UK, INREV and the Investment Association hosted a webinar exploring the new Reserved Investor Fund (RIF), its policy rationale and the practical considerations for fund managers and investors looking to use the structure.
The session featured Simon Chisholm, Chief Investment Officer at Resonance, Melville Rodrigues, Head of Advisory – Real Assets, Apex Group and Co-Head of RE:UK’s Fund Policy Committee, and Tony Page, Policy and Technical Adviser in HMRC’s Collective Investment Schemes Policy Team.
A key message was that the RIF fills a gap in the UK funds market by providing a cost-effective, flexible, UK-based contractual fund structure for institutional and professional investors.
Simon shared Resonance’s experience of launching its Housing Pathways Fund, one of the first funds to use the RIF structure. The evergreen, open-ended residential property fund had a first close of £118 million in July and aims to grow to around £700 million by end 2030. He highlighted the RIF’s ability to bring taxable and tax-exempt investors together in a single UK structure, alongside its flexibility, seeding relief and relatively low operating costs.
Melville, who has had a lead role in designing and advocating for the RIF, outlined the RIF’s key features, including flexible redemption arrangements, multiple unit classes and the ability to operate as a closed, semi-open or open-ended fund. He also highlighted ongoing discussions around:
- extending equivalent property transaction tax reliefs to Scotland and Wales; and
- defined contribution pension schemes (with insurance wrappers) being eligible to invest in the RIF: for example, the RIF has Conditional Permitted Link status like the Long-Term Asset Fund.
Tony explored the RIF's tax treatment. The structure is generally transparent for income tax, allowing income to flow directly to investors, while separate rules govern capital gains and SDLT. The RIF is tax exempt for gains: investors are usually taxed when they dispose of their RIF units rather than when the fund disposes of underlying assets. In addition, he provided an overview of the tax and operational requirements, covering eligibility, the HMRC entry notification process, tax treatment and other compliance obligations.
Key takeaways
- The RIF offers a cost-effective and flexible UK structure for institutional and professional investors.
- Taxable and tax-exempt investors can invest through a single fund.
- Seeding relief can support the transfer of existing property portfolios.
- Industry asks for further reforms could broaden its use, particularly:
- property transaction tax reliefs in Scotland and Wales; and
- for defined contribution pension schemes (with insurance wrappers) being eligible investors in the RIF under permitted links rules.
The webinar concluded with a Q&A covering investor acceptance, tax treatment and the future development of the RIF regime.
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