D8.152 Tax implications

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:

2. 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

3.  

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