Commentary

B5.720 Tax treatment of participants

Business tax
Business tax | Commentary

B5.720 Tax treatment of participants

Business tax | Commentary

B5.720 Tax treatment of participants

Where a reporting fund is not a transparent fund1 (see B5.702), any excess, if any, of reported income over distributions made is treated as an additional distribution made to participants in proportion to their rights on the fund distribution date (see B5.717), or, from 27 May 2011, on such earlier date as the reported income in respect of that reporting period is recognised in the participant's accounts2. For non-transparent funds the excess, if any, of reported income over the income of the fund is treated as additional income of the participant in proportion to their rights3. However, these excesses does not include income relating to rights in certain existing holdings acquired before 1 December 20094.

From 27 May 2011, if a participant disposes of an interest in a reporting fund in a reporting period and TCGA 1992, s 106A (see C2.706) applies for capital gains purposes to identify any part of that interest with an interest acquired in the next reporting period, the participant is treated as still holding that interest at the end of the period of disposal for

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