IFM08630 | Co-ownership Authorised Contractual Schemes (CoACS): Chargeable Gains: part-disposals

If amounts which are not income are paid out of a CoACS or offshore transparent fund the normal chargeable gains rules will treat this as a part-disposal of the holding of units: there may be a liability to tax on any gain accruing at that stage. See section 22 of the Taxation of Chargeable Gains Act 1992 and HMRC’s guidance at CG12940P.

It is unlikely that such a part-disposal would arise in relation to a CoACS as a result of regulatory restrictions: amounts which are not income are unlikely to be paid out when there is no disposal of units. However, a part-disposal may occur in relation to an offshore transparent fund.

Amounts paid out of a CoACS which do not constitute a part-disposal of the holding of units should be treated as a reduction in expenditure - see IFM08620.