Platforms, wraps, IDPS and IDPS-like schemes are not currently deemd as "good" investors for a fund that is trying to satisfy the eligibility requirements for entry into the AMIT regime.
Platforms etc have very large numbers of investors (in the thousands) and a platform investor could easily satisfy the widely held requirement if each investor were to invest into a fund directly.
The current law results in a significant compliance burden for those funds attempting to enter the regime that may have a small number of platform investors but many thousands of individual investors. Tracing through platforms is expensive, cumbersome and creates legal issues with privacy rules. Further it is largely unnecessary as the number of investors in a platform always results in the fund ultimately satisfying the widely held test.
Platforms, wraps, IDPS and IDPS-like schemes should all be considered as "deemed good" investors in the AMIT regime the same way super funds and life companies are.
Thank you for posting your suggestion.
The Minister for Revenue and Financial Services recently announced changes to Australia’s financial services taxation regime, including the Investment Manager Regime and Attribution Managed Investment Trusts. A link to the press release can be found here: http://kmo.ministers.treasury.gov.au/media-release/064-2017/ .
We have provided an extract to the 19 July 2017 press release that you may find of interest below:
Special purpose MITs eligible to access the AMIT regime – single unit holder definition
The Government will amend the meaning of an AMIT so that single unitholder widely held entities can access the AMIT regime. For example, a MIT that has a complying superannuation fund, life company or other genuine widely held investor holding 100 per cent of the units in a trust will be eligible to access the AMIT regime. This change will allow a broader range of MITs to access the AMIT regime. This change will not extend to allowing single unitholder MITs to be a withholding MIT.
While this amendment will not extend to including platforms, wraps or master trusts (commonly referred to as Investor Directed Portfolio Services) in the list of deemed widely-held entities, the Government will consult with industry on broadening the eligibility for these widely held entities to access the concessional tracing rules as part of the Corporate Collective Investment Vehicle public consultation process.
The Board encourages the Sounding Board community to engage in the Corporate Collective Investment Vehicle public consultation process the Government is undertaking.