IFM09225 | Eligibility criteria: Ownership conditions: Genuine diversity of ownership (GDO) condition - Regulation 7

The genuine diversity of ownership (or ‘GDO’) condition is used across a range of tax regimes, including:

• for certain purposes in the Authorised Investment Funds (Tax) Regulations 2006 (S.I. 2006/964)

• for the reporting fund rules in the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001)

• as a condition for making certain elections for the purposes of Schedule 5AAA TCGA 1992 (part of the non-resident capital gains rules that are applicable to collective investment vehicles)

For the purposes of RIFs, Regulation 7 applies the genuine diversity of ownership condition in Regulation 75 of the Offshore Funds (Tax) Regulations 2009 (SI 2009/3001) with modifications. Broadlythose rules apply as if referencesto a “fund” included references to a co-ownership scheme, including a co-ownership scheme which is not an offshore fund, and to relevant multi-vehicle arrangements (see IFM17200). Regulation 7 also modifies the way in which conditions B and C apply for RIF purposes – see IFM17320 and IFM17330.