Commentary

D1.8113 Company holding in a collective investment scheme

Corporate tax
Corporate tax | Commentary

D1.8113 Company holding in a collective investment scheme

Corporate tax | Commentary

D1.8113 Company holding in a collective investment scheme

A company may be a party to an option, a future or a contract for differences (a 'relevant contract') where the underlying subject matter is:

  1.  

    (a)     rights under a unit trust scheme;

  2.  

    (b)     shares in an open-ended investment company; or

  3.  

    (c)     a relevant interest in an offshore fund,

and where the market value of the qualifying investments (see D1.788) of the scheme, company or fund do not exceed 60% of the value of its total investments1. Without special provisions such a contract would be within the capital gains regime where one of the

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