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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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OEICs: umbrella OEICs

 

An umbrella OEIC is an OEIC which is split into a number of separately pooled funds of assets, known as the sub-funds (or parts) of the umbrella company. The umbrella OEIC itself is not treated as a company for tax purposes, but each sub-fund is deemed to be an OEIC. Shareholders in the umbrella company will have rights for the time being in a particular sub- fund of the umbrella company. They are treated as owning shares in the OEIC constituted by that sub-fund.

Where a shareholder exchanges rights in one continuing sub-fund for rights in another, there is a disposal for Capital Gains Tax purposes. If one sub-fund disappears on being merged with another TCGA92/S136 (company reconstruction or amalgamation involving the issue of securities) may provide a form of rollover relief. See CG52700+ for instructions on Section 136.