The CCF is a tax transparent vehicle under Irish law. Pursuant to the Finance Acts, 2003 and 2005, no Irish taxes will be payable in respect of income and gains arising to a CCF on the basis that the income and gains will be regarded as accruing directly to the participants in the CCF in proportion to the value of their interests in the CCF. The CCF is intended to preserve direct access to tax treaty relief currently enjoyed by certain types of investors such as pension funds. Although the Finance Act, 2003 provided that only pension schemes could invest in the CCF, the Finance Act, 2005 has now broadened the category of investor that may invest in the CCF to any investors who are not individuals. Accordingly, only non individuals (such as, for example, companies, partnerships, pension funds and unit trusts) may invest in the CCF.