As offshore funds move towards the next reporting cycle, many managers, particularly those with UK investors, will be preparing for their UK Reporting Fund Status (RFS) obligations. The regime continues to be an important feature of the UK tax landscape and remains a standard expectation for most non-UK fund structures.
Why RFS remains relevant
RFS determines whether UK investors are taxed at capital gains rates on disposal, or at potentially higher income tax rates. For managers distributing into the UK, having reporting status in place can help support investor due diligence and ensure a more predictable tax outcome for allocators.
Who it applies to
The regime covers a broad range of offshore fund vehicles, from Cayman and Luxembourg structures, to Irish ICAVs, Channel Islands funds and US 40-Act vehicles. Eligibility is assessed at the share-class level, and applies to investment funds across hedge, credit, UCITS and alternative strategies.
Key dates for 31 December 2025 year-ends
Managers should keep two core deadlines in mind:
- 31 December 2025 – deadline to register any new share classes that require reporting status for the 2025 period.
- 30 June 2026 – deadline to provide investors with the annual figures and to file the report with HMRC.
These dates apply to each reporting share class and should be factored into fund launch timelines or any new class rollouts.
Annual reporting in brief
Reporting share classes are required to issue annual figures to UK investors and submit the corresponding report to HMRC within six months of the year-end. These disclosures form an important part of the UK investor tax process and are a core component of maintaining reporting status.
Looking ahead
With year-end approaching, managers including those with existing Reporting Fund Status should review whether any new share classes will require registration before 31 December 2025, and ensure that reporting processes are aligned with the 2026 filing deadline. Early planning helps avoid unnecessary pressure and ensures that UK investors receive the information they need in good time for their own reporting obligations.
If you would like to discuss upcoming registrations, reporting processes or the impact of RFS for your structure, please reach out to Mark Baycroft, Partner, Naz Gaffer, Reporting Fund Services Tax Manager, or your usual Financial Services team contact. We’d be happy to help!
