IFM13284 | Offshore Funds: participants in offshore funds: participants within the charge to corporation tax: disposals non-reporting funds: exchanging interest in one fund or share class for another

In certain circumstances The Taxation of Chargeable Gains Act 1992 (‘TCGA’) provides that exchanges of one type of interest for another will not constitute a disposal and acquisition.

Those provisions of TCGA will not apply in some circumstances in the case of exchanges involving interests in non-reporting offshore funds as described in the pages referenced below:

• Exchange of securities for those in another company – IFM13286

• Schemes of reconstruction – IFM13286

• Exchange of interests of different classes – IFM13288