Commentary

C2.803 Unit trusts and open-ended investment companies

Capital gains tax
Capital gains tax | Commentary

C2.803 Unit trusts and open-ended investment companies

Capital gains tax | Commentary

C2.803 Unit trusts and open-ended investment companies

Authorised unit trusts and open-ended investment companies are exempt from capital gains tax, see C1.209.

For capital gains purposes, an authorised unit trust is treated as if it was a company and the rights of a unit holder are treated as if they were shares in that company1. This means that exchanges or conversion of units are treated in the same way as exchanges or conversion of company shares where there is a reorganisation or reconstruction2. There is, however, an exception to this rule regarding treatment as a company in relation to disposals made on or after 1 January 2018 for offshore funds that are transparent funds within the meaning given by the Offshore Funds (Tax) Regulations 20093 (see B5.702)4.

An umbrella scheme is a

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