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 drive the UK government's goals to level up the nation as well as accelerate the infrastructure and green industrial revolutions. 

UK government and regulator representatives 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. 


RIF Latest Update:

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 

27 April 2023 HM Treasury & HMRC issued their consultation (now closed) with legislative options for an unauthorised contractual scheme proposed to be branded the Reserved Investor Fund or RIF.


Melville is grateful for the positive responses to this consultation, including those from AREF and INREV attached. He hopes that, in view of the responses, government will decide to introduce tax legislation the RIF - and UK managers can launch RIFs from April 2024.    

28 February 2023 the Financial Conduct Authority confirmed in its Regulatory Initiatives Grid page 45 that "The Government is progressing work on proposals on the establishment of an unauthorised contractual scheme for professional investors…. through the [Financial Services and Markets] Bill".

Regulatory Initiatives Grid

10 February 2022 HM Treasury published on  its responses to feedback from respondents to its 26 January 2021 Call for Input (CFI). In these responses, the Government confirms that it and the FCA propose to take forward "further work to explore options for the introduction of a new unauthorised contractual scheme fund structure"


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.

Many respondents kindly utilised suggested precedent responses: responses developed by Melville in light of kind collaboration with research, tax, regulatory specialists, senior counsel (John Virgo)  and other network contacts.


Media coverage on the RIF (previously known as the PIF)



29/6/23: INREV Reserved Investor Fund (RIF) Tax and Regulatory briefing


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


05/05/23: Property Week: 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


“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