PMAC Submission on the Draft Legislative Amendments to the Qualified Investments Regime

PMAC supports the proposed modernization of the qualified investments regime announced in Budget 2025. In our submission to the Department of Finance, we identified three areas where targeted refinements would improve clarity, reduce uncertainty, and maintain investor confidence:

  1. The proposed reliance on the existing statutory definition of “investment fund,” which was designed for a different policy purpose and includes diversification and historical requirements that may create unnecessary uncertainty and exclude legitimate specialized funds.
  2. A technical transition issue that could inadvertently trigger Part X.2 tax when moving from the registered investment regime to the new rules.
  3. The loss of a publicly available list of registered investments, which currently helps investors verify qualified investment status.

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