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HMRC internal manual

Company Taxation Manual

Particular bodies: investment trusts

For tax purposes, an ‘investment trust’ is defined at, and approved under, CTA10/S1158 and S1159. These provisions were amended by FA11/S49. In the same act, S50 added a power at CTA10/S622A to make regulations about the treatment of the transactions of investment trusts and about their approval. See The Investment Trust (Approved Company) (Tax) Regulations 2011, SI2011/2999.

Approved companies are exempt from CT on chargeable gains under TCGA92/S100 (1). The Regulations provide that specified transations of investment trusts will always be treated for the purposes of the Corpration Tax Acts as being entered into for the purposes of investment rather than in the course of a trade. See also CTM47100 onwards.