funds and unit trusts) may invest in the CCF. While the CCF is treated as tax transparent under Irish law, it will be a matter for the jurisdiction in which the investor is resident for tax purposes to determine whether similar tax treatment will be granted in that jurisdiction to the CCF. Similarly, the tax authority of the jurisdiction in which the income arises must also recognise the tax transparency of the CCF. In order to facilitate the tax transparency, it is considered that the CCF should have the following characteristics which would distinguish it from a typical unit trust or investment company structure: (a) no meetings of investors should be permitted; (b) units should not be freely transferable but should be redeemable; and (c) no redemption charge should be levied. It is also necessary that income derived from the CCF be distributed annually, in proportion to each investor's holding in the CCF. This will ensure that the income is both accounted for and taxed on a current basis. Investors will be provided with an annual breakdown of income by type and source. Although tax advice should be obtained regarding the tax transparency status of any CCF in the jurisdictions in which the CCF's investors and underlying investments are located, indications are that the CCF is likely to be treated as tax transparent in the following jurisdictions: Austria, Belgium, Canada, France, Germany, Norway, Switzerland, the Netherlands and the United States. (Source: Arther Cox (Dublin)) As discussed in a recent Finance Week article, there are huge performance implications alone in using a CCF, compared to the same investment via an Irish Variable Capital Company (VCC). In the example given, if a fund manager invested £1bn in the MSCI Euro index and performed only equal to that index, a CCF would have created an additional return of £57.5 million over the past 10 years. See also Qualifying investor alternative investment fund (QIAIF) Irish Financial Services Regulatory Authority Common fund External links Irish Financial Services Regulatory Authority DFIA paper on CCFs European Pensions News Article FinanceWeek Article Investment funds Economy of the Republic of Ireland