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Contents

Official guidance
Investment Funds Manual

IFM09300 · Taxation of investors in RIFs

  • IFM09305 · Taxation of investors: Introduction
  • IFM09310 · Taxation of investors: Income
  • IFM09320 · Taxation of investors: Chargeable Gains: introduction
  • IFM09325 · Taxation of investors: Chargeable Gains: calculation
  • IFM09330 · Taxation of investors: Chargeable gains: Umbrella scheme
  • IFM09335 · Taxation of investors: Chargeable gains: Co-ownership schemes that are neither a RIF or CoACS
  • IFM09340 · Taxation of investors: Chargeable gains: Deemed Disposals: events causing a deemed disposal
  • IFM09345 · Taxation of investors: Chargeable gains: Deemed disposal: calculation of the gain on a deemed disposal and reacquisition of units at market value
  • IFM09350 · Taxation of investors: Chargeable gains: Deemed disposal: time at which gains accrue
  • IFM09355 · Taxation of investors: Chargeable gains: Deemed Disposal: notification requirement
  • IFM09360 · Taxation of investors: Capital Allowances
  1. Taxation of investors in RIFs: contents
  2. Taxation of investors: Chargeable gains: Umbrella scheme

IFM09330 | Taxation of investors: Chargeable gains: Umbrella scheme

From HM Revenue & Customs · Investment Funds Manual

Regulation 52(2) amends section 99A(6) TCGA 1992 “Treatment of umbrella schemes” so that where a RIF is structured as an ‘umbrella scheme’, participants’ interests in the umbrella scheme are disregarded and each sub-scheme is treated as a separate collective investment scheme for capital gains purposes. Participants are therefore treated as holding units in the sub-scheme and not the umbrella scheme.

For further information regarding how the rules for RIFs generally are adapted for umbrella schemes – see IFM09850.

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