PM232500 | AIFM: Overview

An AIFM firm is a partnership, the business of which is managing one or more AIFs or which carries out the function of managing AIFs as a delegate. As part of EU-wide strategy for investor protection, AIFM firms are required to subject part of the “remuneration” of key individuals to performance conditions and to defer when those individuals can access that remuneration.

A member of an AIFM firm (including an LLP), is chargeable on the profits of the partnership as they arise rather than when they are received.

The AIFM tax provisions allow the AIFM partnership to elect to be treated as a partner in itself in order to pay tax on a member’s remuneration on behalf of the member.

If it does so, the AIFM firm is treated as an individual member of the partnership, not as a non-individual member for the purposes of the mixed membership rules.

For further information on how the excess profit allocation rules interact with the AIFM deferral arrangements, see PM233000.