Trends in global pension funds : the Irish common contractual fund

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Summary: Pension funds often use a pooled vehicle to structure their investments. Pooling of assets can lead to economies of scale and reduced costs, as well as the opportunity for greater investment diversification and effective management of the fund's investment policy. While a pooled vehicle can be used for cross-border investments, one of the challenges of global pooling is the preservation of tax neutrality to the pension fund. In the global environment, the key tax issue is withholding taxes. Withholding taxes represent an absolute cost to the pension fund's return on investment. The interposition of a global pooling vehicle between the pension fund and the investment can complicate the withholding tax issue and lead to additional tax costs. As pension funds have come under increasing pressure in recent years, there has been renewed interest in the use of tax-effective global pooling vehicles to structure pension fund investments. One vehicle being promoted is the Irish common contractual fund (CCF). This article discusses the characteristics of the Irish CCF in the context of current issues faced by global pension funds, the tax treatment of a CCF under Canada's Income Tax Act, and the suitability of this pooling vehicle for Canadian pension funds

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Summary: Pension funds often use a pooled vehicle to structure their investments. Pooling of assets can lead to economies of scale and reduced costs, as well as the opportunity for greater investment diversification and effective management of the fund's investment policy. While a pooled vehicle can be used for cross-border investments, one of the challenges of global pooling is the preservation of tax neutrality to the pension fund. In the global environment, the key tax issue is withholding taxes. Withholding taxes represent an absolute cost to the pension fund's return on investment. The interposition of a global pooling vehicle between the pension fund and the investment can complicate the withholding tax issue and lead to additional tax costs. As pension funds have come under increasing pressure in recent years, there has been renewed interest in the use of tax-effective global pooling vehicles to structure pension fund investments. One vehicle being promoted is the Irish common contractual fund (CCF). This article discusses the characteristics of the Irish CCF in the context of current issues faced by global pension funds, the tax treatment of a CCF under Canada's Income Tax Act, and the suitability of this pooling vehicle for Canadian pension funds