SI2006/964 Regulation 14E – ‘investment transactions’ of diversely owned funds

Regulation 14E prevents defined financial transactions carried out by diversely owned authorised investment funds (AIFs) from being characterised as trading transactions for tax purposes. This rule gives diversely owned AIFs certainty that gains on the realisation of certain types of investments, which would not be chargeable gains (see CTM48215), cannot be re-characterised as profits arising from a trade which would then be taxable as income.

The rule applies where an AIF:

carries out an ‘investment transaction’ (see CTM48282) in an accounting period; and

Want to read more?

This content requires a Croner-i Tax and Accounting subscription.

Existing subscriber? Log in

No subscription?

Contact us to discuss your requirements.