Commentary

C2.1162 Property rich collective investment vehicles—basic rules

Capital gains tax
Capital gains tax | Commentary

C2.1162 Property rich collective investment vehicles—basic rules

Capital gains tax | Commentary

C2.1162 Property rich collective investment vehicles—basic rules

The term collective investment scheme is specifically defined under the legislation (see C2.1161). It is only entities within that definition and their investors that are subject to the rules described below.

For capital gains purposes, all offshore CIVs apart from partnerships (or those that are already companies) are, from 6 April 2019, deemed to be companies, and interests in them treated as shares. This deeming treatment has two effects for capital disposals made by non-resident CIVs on or after 6 April 20191:

  1.  

    •     gains on direct disposals of UK land by offshore CIVs (other than co-ownership authorised contractual schemes (CoACs)) are chargeable to corporation tax (in a similar way

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