Commentary

D8.152 Tax implications

Corporate tax
Corporate tax | Commentary

D8.152 Tax implications

Corporate tax | Commentary

D8.152 Tax implications

The rules applicable to FINROFs ensure that on the disposal of units in such funds a tax charge is imposed on the UK-resident investor, as opposed to the authorised investment fund itself.

The charge arises if1:

  1.  

    (a)     there is a disposal of either:

    1.  

      (1)     units in a FINROF; or

    2.  

      (2)     units in an authorised investment fund that had been a FINROF at some time since the date of acquisition and disposal and no valid deemed disposal election had been made (D8.154); and

  2.  

    (b)     as a result of the disposal there is an income gain (chargeable to income

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