RIF - Reserved Investor Fund

Melville is the key architect and lead advocate of the UK Reserved Investor Fund (RIF) proposal. He is recognised as the progenitor of the RIF:

Melville has been instrumental in designing of the RIF:

  • unauthorised co-ownership AIF
  • closed-ended or a hybrid
  • limited to institutional investors & (£1m min. commitment) high net worth investors
  • effectively tax transparent & tradable units i.e. transfers not inhibited by transaction tax
  • unlisted & operates within the UK AIFMD regime with a UK AIFM & UK depositary
  • plugs a gap in the UK funds regime, particularly for real estate fund managers  


RIF key attractions:

  • strengthens the UK's fund offering and improves competitiveness  
  • lowers the barriers for SME asset managers to launch new products
  • speed to market and low-cost, in terms of launch and operation
  • increases the number of closed-ended or hybrid investment vehicles in the UK
  • promotes investment in longer-term, less liquid assets
  • will assist in getting growth going in the UK economy as well as creating jobs and  opportunities

  • addresses investors' preference for an onshore fund structure that is FCA regulated
  • a "quick win" legislative solution

The RIF will facilitate fund management houses support the UK government's goals to  accelerate the infrastructure and green industrial revolutions including as a structure for publicprivate partnerships. 

UK government and regulator officials have constructively engaged with this proposal. There is widespread industry support for the RIF initiative, including from institutional investors as well as large and SME fund managers.


The 6 March Spring 2024 Budget saw a welcome announcement from the UK government on the RIF. The government confirmed it is proceeding with tax rules to introduce the RIF. It has since legislated the Finance (No.2) Act 2024 Section 20 and has consulted on draft tax regulations for the RIF: the consultation closed on 14 May 2024.See this link to the AREFand INREV responses to the consultation: https://www.aref.org.uk/resource/professional-investor-fund.html



Melville was involved in preparing these and other industry responses.


On 21 May 2024 House of Commons Public Bill Committee debated Finance (No. 2) Bill Clause 20 relating to the RIF, and accordingly ordered Clause 20 to stand part of the Bill.


Melville is particularly grateful for, and welcomes, these statements in the debate:


The then Exchequer Secretary to the Treasury (Gareth Davies MP):


“It is a great pleasure, as always, to see you in the Chair, Mrs Latham. Clause 20 begins the process of introducing legislation for a new type of investment fund—the reserved investor fund, which I will refer to from now on as the RIF. At Budget 2020, the Government announced a review of the UK’s funds regime, covering tax and relevant areas of regulation. The review had an overarching objective to make the UK a more attractive location to set up, manage and administer funds, as well as ensuring that UK investors can access a wide enough range of investment vehicles to suit their needs. In the years since, the Government have made a number of successful reforms. In order to build on these successes, the Government announced at spring Budget 2024 that we would be proceeding with the RIF.


The RIF will fill a gap in the UK’s existing fund offering by creating an onshore alternative to existing non-UK fund vehicles that are commonly used to hold UK real estate. Clause 20 provides a definition of the RIF and provides a power for the Treasury to make detailed tax rules through secondary legislation, consistent with the approach taken when introducing tax rules for other investment funds. A later statutory instrument will set out detailed tax rules for the RIF. The regulations will set out supplementary qualifying conditions for a RIF, entry and exit provisions, and rules that deal with breaches of one or more qualifying conditions.


The UK has a world-leading asset management sector. The RIF will play an important role in supporting that leadership by making the UK a more competitive destination for our fund management industry. Indeed, stakeholders from the financial services industry have already shown considerable support for the RIF. I therefore commend the clause to the Committee”.


The then Shadow Exchequer Secretary to the Treasury (Tulip Siddiq MP):


“It is a pleasure to serve on this Committee under your chairmanship, Mrs Latham. I am pleased to respond to clauses 20 to 24 on behalf of the Opposition. Clause 20, as the Minister set out, introduces the necessary powers to set the scope and design of the tax regime and rules for the RIF. Labour welcomes the introduction of the RIF, as it will add to the investment products available here in the UK, particularly for the UK commercial real estate sector.”


Following the 4 July UK general election, the new Parliament is expected to first meet on 9 July and the State Opening of Parliament to take place on 17 July. In view of the cross-party support for the RIF, Melville hopes that soon into the new Parliament the Treasury will exercise its power to make detailed tax rules for the RIF through secondary legislation, so (when the detailed tax rules take effect) managers will be entitled to launch RIFs.


RIF Further Updates:

24 May 2024 Royal Assent of Finance (No.2) Act 2024 with Section 20 containing provisions for the RIF.


21 May 2024 House of Commons Public Bill Committee ordered Finance (No.2) Bill 2024 Clause 20 to stand part of the Bill.


2 April 2024 The government's draft tax regulations for the RIF.


13 March 2024 Finance (No.2) Bill 2024 Clause 20 refers to tax legislation for the RIF.


6 March 2024 the government is proceeding with tax rules to introduce the RIF.


30 November 2023 the Financial Conduct Authority confirmed in its Regulatory Initiatives Grid page 44 that "The Government is progressing work on proposals on the establishment of an unauthorised contractual scheme for professional investors."

Regulatory Initiatives Grid

29 June 2023 Royal Assent of the Financial Services and Markets Act 2023, with Section 64 establishing RIFs (referred to as unauthorised co-ownership AIFs) in primary legislation:


See also paragraphs 475-482 and 1317-1324 inclusive explanatory notes 

Melville is very grateful to:

- AIMA, AREF, BPF, The Investment Association, INREV, IPF and other industry organisations;

- fund managers, institutional investors, tax advisers, law firms and other professionals

for supporting the RIF.

He appreciates the kind assistance from research, tax, regulatory specialists, senior counsel (John Virgo) and other contacts in developing the design of the RIF.



21/03/24: Seize the RIF opportunity - Alternative Investment Management Association/      Association of Real Estate Funds/British Property Federation/The Investment Association/European Investors in Non-Listed Real Estate/Investment Property Forum/Real Estate Investors’ Forum



17/05/24 The Goan EveryDay: Goan spearheads plans for new type of investment fund in UK


16/05/24 UK REIIF: News: New Reserved Investor Fund to Boost Town Centre Regeneration


15/05/24: IPE Real Assets: News: Real estate associations call for launch of UK reserved investor fund this year


15/05/24: Property Week: Industry ‘encouraged’ by draft regulations for Reserved Investor Fund

Industry ‘encouraged’ by draft regulations for Reserved Investor Fund | News | Property Week

19/04/24: Tax Journal: the new Reserved Investor Fund: what we know so far

The new Reserved Investor Fund: what we know so far (taxjournal.com)

5/04/24: IPE Real Assets: Guest view: How should UK real estate managers choose between a RIF and REIT?


22/03/24: IPE Real Assets: Guest view: UK fund managers – seize the RIF opportunity


07/03/24: UK to legislate for reserved investor funds in boost for real estate managers


06/03/24: Property EU: UK to proceed with RIFs much to fund industry delight


19/05/23: IPE Real Assets: Guest view: Let’s get the UK’s Reserved Investor Fund done


05/05/23: Government launch of new fund vehicle proposals to boost real estate investment


28/04/23: IPE Real Assets: UK government consults on creation of ‘reserved investor fund’


08/12/22: Property Week:PIF changes to boost property funds sector


02/12/22: IPE Real Assets: UK government prepares to create new onshore closed-ended funds


16/04/22: Apex Group, Professional Investor Funds could fill the UK fund sector gap


18/03/21: Property Week, Professional Investor Funds (PIFs) could fill the UK fund sector gap


24/2/21: IPE Real Assets, UK funds review: chance to create real estate fund that meets institutional needs


3/2/21: Property Week, Government call for input on property fund structure change


16/12/20: Property Week, Government launches second consultation on REIT tax structure


3/8/20: IPSX,  Podcast: Onshore versus offshore


2/7/20: AREF & IPF, Webinar: PIF Proposal Explained


13/05/20: Lexis Nexis,  A Gap in the market


4/3/20: FTfm, UK investment body lobbies for property fund revamp


May/June 2019: IPE Real Assets, A new UK fund structure


"Very well done indeed on getting the Government finally to bring in RIFs – a most tenacious effort and hopefully it will be well-appreciated by the real estate capital management industry. We certainly do." March 2024

- Hugo Llewelyn, CEO, Newcore Capital

“Huge credit goes to Melville Rodrigues who has pushed forward this initiative from day one”. March 2024

- John Forbes, Principal, John Forbes Consulting LLP

"Congratulations on seeing the ‘birth’ of the RIF! Clearly wouldn’t have happened absent your spearheading of the initiative. It’s a rarity in our world that people get to see such a ‘complete’ example of an initiative that is proposed, worked up, then endorsed and launched by the Government – you should be very proud of it." March 2024

- Head of Investment Managment Tax, Global Fund Manager   

"The more I read about the RIF, the more I wish someone had taken your initiative years ago!"  January 2024

- UK Real Estate Fund Manager

“Thank you very much for the opportunity to work with you on this exciting and certain to be market shaping new vehicle!” June 2023

- UK Tax and Funds Specialist, one of the Big Four accounting firms

"Melville, 100 x well done on your remarkable achievement!" May 2023

- Tax Specialist, Magic Circle law firm

“Special thanks to Melville for all his initiative, leadership and hard work in progressing the PIF proposal. We believe the PIF will be an excellent product that would introduce an important new choice for investors and that the real estate investment industry would enthusiastically take it up.” October 2022

 - Jeff Rupp INREV Director of Public Affairs

"What you have done in terms of spearheading this new fund structure and pushing it through as well as ironing out all the structural difficulties so that it is as attractive as possible for the asset management market is nothing short of ground-breaking." June 2022

- Funds Specialist, Magic Circle law firm

"The time has come to modernize, standardise and regulate a form of tax-transparent closed-ended or hybrid fund. The PIF submission is welcome and timely." August 2020

- Andrew Baum, Professor of Practice, Said Business School, University of Oxford

"There appears to be a clear and genuine need/preference for them to invest via an onshore tax-transparent vehicle. PFR estimate that only 25% of €260bn in AuM in closed-end funds launched by UK based fund managers and targeting UK and European assets in the last 10 years have utilised a UK onshore fund structure. There is a clear opportunity for the UK fund management industry" September 2020 

- Jane Fear, Director, Property Funds Research