D8.152 Tax implicationsThe 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: (a) there is a disposal of either: (1) units in a FINROF; or (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 (b) as a result of the disposal there is an income gain (chargeable to income
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:
(a) there is a disposal of either:
(1) units in a FINROF; or
(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
(b) as a result of the disposal there is an income gain (chargeable to income
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