The definition of Special Investment Funds (SIFs) which benefit from the VAT exemption for fund management services is currently unclear and relies on EU law. The Chancellor may use the Budget as an opportunity to publish the government’s response to HMRC’s consultation 221130_VAT_on_fund_management_condoc.pdf ( on the VAT treatment of fund management services. The scope of the consultation was narrow, looking to codify case law and UK policy on SIF status with a new definition (in addition to the funds that already have SIF status). Taking this forward would be welcome.

The broader question of whether the scope of the exemption should be extended to make the UK a more attractive jurisdiction for fund management is unlikely to be addressed in this month’s budget. However, in the longer term this question could still be considered. Clarification would also be welcome on the definition of “management” and how the exemption should apply where management is outsourced to third parties, or where management services cover both SIFs and non-SIFs.