1. Investment vehicle
  2. 1. Form
    1. UK Limited Partnership [Private Fund Limited Partnership]
    2. UK Exempt Unauthorised Unit Trust (EUUT)
    3. UK Real Estate Investment Trust (UK REIT)
    4. Qualifying Asset Holding Company (QAHC)
    5. Reserved Investor Fund (RIF)
  3. 2. Tax Treatment
    1. UK Limited Partnership [Private Fund Limited Partnership]
    2. UK Exempt Unauthorised Unit Trust (EUUT)
    3. UK Real Estate Investment Trust (UK REIT)
    4. Qualifying Asset Holding Company (QAHC)
    5. Reserved Investor Fund (RIF)
  4. 3. Transfer Tax
    1. UK Limited Partnership [Private Fund Limited Partnership]
    2. UK Exempt Unauthorised Unit Trust (EUUT)
    3. UK Real Estate Investment Trust (UK REIT)
    4. Qualifying Asset Holding Company (QAHC)
    5. Reserved Investor Fund (RIF)
  5. 4. Listable
    1. UK Limited Partnership [Private Fund Limited Partnership]
    2. UK Exempt Unauthorised Unit Trust (EUUT)
    3. UK Real Estate Investment Trust (UK REIT)
    4. Qualifying Asset Holding Company (QAHC)
    5. Reserved Investor Fund (RIF)
  6. 5. Open- or closed-ended
    1. UK Limited Partnership [Private Fund Limited Partnership]
    2. UK Exempt Unauthorised Unit Trust (EUUT)
    3. UK Real Estate Investment Trust (UK REIT)
    4. Qualifying Asset Holding Company (QAHC)
    5. Reserved Investor Fund (RIF)
  7. 6. Regulatory Supervision
    1. UK Limited Partnership [Private Fund Limited Partnership]
    2. UK Exempt Unauthorised Unit Trust (EUUT)
    3. UK Real Estate Investment Trust (UK REIT)
    4. Qualifying Asset Holding Company (QAHC)
    5. Reserved Investor Fund (RIF)
  8. 7. Investor Restrictions
    1. UK Limited Partnership [Private Fund Limited Partnership]
    2. UK Exempt Unauthorised Unit Trust (EUUT)
    3. UK Real Estate Investment Trust (UK REIT)
    4. Qualifying Asset Holding Company (QAHC)
    5. Reserved Investor Fund (RIF)
  9. 8. Pros
    1. UK Limited Partnership [Private Fund Limited Partnership]
    2. UK Exempt Unauthorised Unit Trust (EUUT)
    3. UK Real Estate Investment Trust (UK REIT)
    4. Qualifying Asset Holding Company (QAHC)
    5. Reserved Investor Fund (RIF)
  10. 9. Cons
    1. UK Limited Partnership [Private Fund Limited Partnership]
    2. UK Exempt Unauthorised Unit Trust (EUUT)
    3. UK Real Estate Investment Trust (UK REIT)
    4. Qualifying Asset Holding Company (QAHC)
    5. Reserved Investor Fund (RIF)
  11. 10. Best Used For
    1. UK Limited Partnership [Private Fund Limited Partnership]
    2. UK Exempt Unauthorised Unit Trust (EUUT)
    3. UK Real Estate Investment Trust (UK REIT)
    4. Qualifying Asset Holding Company (QAHC)
    5. Reserved Investor Fund (RIF)

Updated on January 2026

Investment vehicle

  • UK Limited Partnership [Private Fund Limited Partnership]
  • UK Exempt Unauthorised Unit Trust (EUUT)
  • UK Real Estate Investment Trust (UK REIT)
  • Qualifying Asset Holding Company (QAHC)
  • Reserved Investor Fund (RIF)

1. Form

UK Limited Partnership [Private Fund Limited Partnership]

  • Limited Partnership

UK Exempt Unauthorised Unit Trust (EUUT)

  • Unit Trust

UK Real Estate Investment Trust (UK REIT)

  • Is an elected tax status for UK tax resident companies (can be elected by companies incorporated in other jurisdictions if tax resident in UK).

Qualifying Asset Holding Company (QAHC)

  • Is an elected tax status for UK tax resident holding companies (can be elected by companies incorporated in other jurisdictions if tax resident in UK).

Reserved Investor Fund (RIF)

  • Unauthorised co-ownership contractual scheme.

2. Tax Treatment

UK Limited Partnership [Private Fund Limited Partnership]

  • Tax transparent

UK Exempt Unauthorised Unit Trust (EUUT)

  • Effectively tax-free at trust level

UK Real Estate Investment Trust (UK REIT)

  • Tax exempt status for UK property investment business, subject to meeting REIT conditions. 
  • Can have up to 25% of business related to other activities but other activities may be taxable.

Qualifying Asset Holding Company (QAHC)

  • Tax exempt status for ringfenced investment business such as for qualifying shares and non-UK land (not UK land)
  • Investors broadly taxed as if they had invested direct
  • Conditions apply including for ownership and must have a qualifying investment strategy.

Reserved Investor Fund (RIF)

  • Transparent for income tax purposes.
  • Treated as opaque for UK tax on chargeable gains, but RIF is exempt, with investors being subject to tax on disposals of units in the RIF (subject to their status).

3. Transfer Tax

UK Limited Partnership [Private Fund Limited Partnership]

  • 5% on direct underlying UK property GAV above GBP 250,000 (with lower rates applied for the portion of GAV below GBP 250,000).

UK Exempt Unauthorised Unit Trust (EUUT)

  • 0.5%, but in certain circumstances can be nil.

UK Real Estate Investment Trust (UK REIT)

  • 0.5% if UK Company. 
  • Will depend on country if non-UK (e.g. Jersey).

Qualifying Asset Holding Company (QAHC)

  • 0.5% if UK Company 
  • Will depend on country if non-UK (e.g. Jersey)

Reserved Investor Fund (RIF)

  • No transfer tax on transfers of RIF units.

4. Listable

UK Limited Partnership [Private Fund Limited Partnership]

  • No

UK Exempt Unauthorised Unit Trust (EUUT)

  • No

UK Real Estate Investment Trust (UK REIT)

  • Yes. 
  • An exemption from listing is available where 70% of direct / indirect ownership is institutional.

Qualifying Asset Holding Company (QAHC)

  • No

Reserved Investor Fund (RIF)

  • No

5. Open- or closed-ended

UK Limited Partnership [Private Fund Limited Partnership]

  • Can be closed or open-ended

UK Exempt Unauthorised Unit Trust (EUUT)

  • Can be closed or open-ended

UK Real Estate Investment Trust (UK REIT)

  • Closed-ended (but buy backs / capital reductions possible)

Qualifying Asset Holding Company (QAHC)

  • Closed-ended (but buy backs possible)

Reserved Investor Fund (RIF)

  • Can be closed or open-ended

6. Regulatory Supervision

UK Limited Partnership [Private Fund Limited Partnership]

  • UK AIFMD or CIS regimes may apply, in which case appointment of an FCA regulated AIFM / operator required (as applicable).
  • A PFLP must be a CIS.

UK Exempt Unauthorised Unit Trust (EUUT)

  • UK AIFMD or CIS regimes may apply, in which case appointment of an FCA regulated AIFM / operator required (as applicable).

UK Real Estate Investment Trust (UK REIT)

  • UK AIFMD rules apply if REIT is an AIF, with either the REIT (internal management) or AIFM (external management) regulated by FCA.
    UK or other jurisdiction Prospectus rules apply if “listed”.

Qualifying Asset Holding Company (QAHC)

  • UK AIFMD or CIS regimes may apply, in which case appointment of an FCA regulated AIFM required.

Reserved Investor Fund (RIF)

  • Must be an AIF and so must have AIFM regulated by the FCA.

7. Investor Restrictions

UK Limited Partnership [Private Fund Limited Partnership]

  • Limited to institutional, high net worth or knowledgeable investors

UK Exempt Unauthorised Unit Trust (EUUT)

  • Only available to UK tax exempt investors, i.e. pension funds and charities

UK Real Estate Investment Trust (UK REIT)

  • No, but for unlisted vehicles, there are specific investor requirements.

Qualifying Asset Holding Company (QAHC)

  • FCA financial promotion rules
  • Tax ownership requirements - investors other than good (e.g. institutional and diverse ownership investors) not to exceed 30%

Reserved Investor Fund (RIF)

  • Must satisfy genuine diversity of ownership condition, or be controlled by certain qualifying institutional investors.

8. Pros

UK Limited Partnership [Private Fund Limited Partnership]

  • Tax transparent and highly flexible
  • Often combined with other investment vehicles

UK Exempt Unauthorised Unit Trust (EUUT)

  • Tax efficiency

UK Real Estate Investment Trust (UK REIT)

  • Tax exempt status for UK property investment.
  • Can be part of a fund. 
  • Can have underlying investment vehicles and joint ventures.

Qualifying Asset Holding Company (QAHC)

  • Tax efficiency including for ring fenced business.
  • Withholding tax exemptions on dividends and interest

Reserved Investor Fund (RIF)

  • Tax efficient including on transfer of units in RIF.
  • Onshore vehicle which has some similar features to a Jersey / Guernsey Property Unit Trust.

9. Cons

UK Limited Partnership [Private Fund Limited Partnership]

  • Illiquid and can be subject to transfer tax.
  • No access to AIFMD marketing passport as non-EU AIF.

UK Exempt Unauthorised Unit Trust (EUUT)

  • Tax exempt investors only

UK Real Estate Investment Trust (UK REIT)

  • Range of REIT conditions which must be met to maintain REIT status.

Qualifying Asset Holding Company (QAHC)

  • Entry Specific holding company regime and limitations on activities.

Reserved Investor Fund (RIF)

  • Conditions must be met regarding asset ownership (in particular regarding UK property ownership) and investors.

10. Best Used For

UK Limited Partnership [Private Fund Limited Partnership]

  • Property, private equity, venture capital, credit and infrastructure funds.
  • UK property joint ventures with exempt taxpayers.

UK Exempt Unauthorised Unit Trust (EUUT)

  • Pooled property for exempt investors

UK Real Estate Investment Trust (UK REIT)

  • UK property investment.
    Potential “unlisted” use as a holding vehicle within a fund structure.

Qualifying Asset Holding Company (QAHC)

  • Use as an investment vehicle for qualifying investments.
  •  Comparable to Luxembourg asset holding companies (AHCs).

Reserved Investor Fund (RIF)

  • A new regime as of March 2025, but predicted to be useful for government and local authority pension scheme investment.