Commentary

D8.181 Definition of unauthorised unit trust

Corporate tax
Corporate tax | Commentary

D8.181 Definition of unauthorised unit trust

Corporate tax | Commentary

D8.181 Definition of unauthorised unit trust

The provisions in this article apply from 6 April 2014, unless the UUT is a mixed trust (D8.186) in which case the provisions at D8.175 continue to apply.

An unauthorised unit trust (UUT) can either be an exempt unauthorised unit trust (EUUT), or a non-exempt unauthorised unit trust (NEUUT).

Exempt unauthorised unit trust

In order to be an EUUT the following conditions must be satisfied1:

  1.  

    •     its trustees are UK resident for the period

  2.  

    •     throughout the period all of its unit holders are eligible investors (ie exempt from UK CGT or corporation tax for reasons other than residence2, although for the purposes of this condition no account is taken of the possibility of a charge to corporation tax on income in respect of a gain accruing on a disposal by an

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