Updated on January 2026

Investment vehicle

  • Authorised Contractual Scheme (ACS)
  • Open-Ended Investment Company (OEIC)

1. Form

Authorised Contractual Scheme (ACS)

  • ACSs can be established in two legal forms:
    • as authorised co-ownership schemes, and
    • as authorised limited partnership funds.

Open-Ended Investment Company (OEIC)

  • Corporate entity

2. Tax Treatment

Authorised Contractual Scheme (ACS)

  • Tax transparent 
  • ACS itself is not a taxable entity for UK tax purposes and is not subject to tax in the UK on income or gains arising on underlying investments
  • In some markets, domestic withholding tax exemptions may apply to the ACS

Open-Ended Investment Company (OEIC)

  • OEIC itself is exempt from tax on chargeable gains; may be subject to corporation tax at 25% on income. Option for election into Property Authorised Investment Fund (PAIF) regime, which, can bring tax advantages making the fund tax efficient, although not transparent.
  • How investors are treated for tax will depend on residence.

3. Transfer Tax

Authorised Contractual Scheme (ACS)

  • Unlikely if an authorised co-ownership scheme.

Open-Ended Investment Company (OEIC)

  • Will depend on asset class OEIC holds.

4. Listable

Authorised Contractual Scheme (ACS)

  • No

Open-Ended Investment Company (OEIC)

  • Yes (but would be unusual)

5. Open- or closed-ended

Authorised Contractual Scheme (ACS)

  • Open-ended

Open-Ended Investment Company (OEIC)

  • Open-ended

6. Regulatory Supervision

Authorised Contractual Scheme (ACS)

  • Vehicle authorised by FCA in UK and must comply with ACS Regulations as well as broader FCA rules (such as COLL).
  • The ACS may be structured as either a UCITS or an AIF and either of these Directives and their Regulations would therefore also be relevant.

Open-Ended Investment Company (OEIC)

  • Vehicle authorised by FCA in UK and must comply with OEIC Regulations as well as broader FCA rules (such as COLL).
  • As an OEIC may be structured as either a UK UCITS or a UK AIF and either of these Directives (as implemented in the UK post-Brexit) and their UK Regulations would therefore also be relevant.
  • A UK UCITS may not invest in direct real estate - and so real estate exposure is normally achieved by UCITS through investment in REITs and other property investment companies.

7. Investor Restrictions

Authorised Contractual Scheme (ACS)

  • ACSs are available only to certain types certain types of investor, being (1) a professional ACS investor (a professional client for the purposes of MiFID; (2) a large ACS investor (being a person who in exchange for units makes a payment of not less than GBP 1m or contributes property with a value of not less than GBP 1m); and (3) a person who already properly holds units in the ACS.
  • This restricts the usually wide investment criteria for UK UCITS and NURSs and must be considered alongside the QIS or LTAF requirements.

Open-Ended Investment Company (OEIC)

  • Will depend on whether the OEIC is a UK UCITS, a non-UCITS retail scheme (NURS), a Qualified Investor Scheme (QIS) or a Long Term Asset Fund (LTAF).
  • The former 2 are suitable for mass market retail; the latter for sophisticated or professional clients with LTAFs having some potential for retail exposure (see later entry on LTAF).

8. Pros

Authorised Contractual Scheme (ACS)

  • Tax efficiency

Open-Ended Investment Company (OEIC)

  • Suitable for a large number of investors
  • Open-ended: so flexible
  • FCA regulated – and badge of authorisation seen as a benefit to certain investor types.

9. Cons

Authorised Contractual Scheme (ACS)

  • Investment restrictions (if a UCITS or NURS). Much greater flexibility for QIS and LTAF.
  • Regulated framework (which may be a benefit depending on fund requirements and target investor).

Open-Ended Investment Company (OEIC)

  • Investment restrictions (if a UCITS or NURS). Much greater flexibility for QIS and LTAF.
  • Regulated framework (which may be a benefit depending on fund requirements and target investor).

10. Best Used For

Authorised Contractual Scheme (ACS)

  • UK institutional Investment (including local government pension schemes and other DC schemes).
  • A number of LTAFs have been established as co-ownership ACSs.

Open-Ended Investment Company (OEIC)

  • Retail investment (if a UCITS or NURS).
  • A number of LTAFs that have launched have been structured as OEICs.