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HMRC internal manual

Capital Gains Manual

Company reconstructions: company: TCGA92/S139: unit/investment trusts


TCGA92/S139 does not apply to transfers to

  • authorised unit trusts, see CG41330
  • unit trusts which are exempt from Capital Gains Tax because all the unit holders are exempt, see CG41352
  • approved investment trusts, see CG41410.
  • Venture Capital Trusts (where the transfer is on or after 17March 1998), see CG57450+.

This is because all these bodies are exempt from tax on chargeable gains.