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HMRC internal manual

Company Taxation Manual

Tax elected funds (TEFs): introduction & conditions of membership for the TEF regime: the genuine diversity of ownership (GDO) condition

Under regulation 69Z45 SI2006/964 the tax elected fund (TEF) must meet the genuine diversity of ownership (GDO) condition set out in regulation 9A SI2006/964. This condition is to prevent the regime from being manipulated by a small group of people or a larger connected group who may intend to gain a tax advantage. The GDO sets out three sub-conditions (A to C) that must be met by a TEF which are explained in detail at CTM48160.

Advance clearance

There is a clearance arrangement (CTM48165) to enable proposed TEFs to check in advance that their proposed arrangements will meet the GDO.