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HMRC internal manual

International Manual

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Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: "investment transaction": transactions in carbon emission trading products

Carbon emission trading products

Regulation 11 of The Investment Manager (Specified Transactions) Regulations 2009 admits transactions in carbon emission trading products.

Carbon emission trading products for the purposes of regulation 11 are either:

  • Community tradable emissions allowances; or
  • Transferable units issued pursuant to the Kyoto Protocol.

Community tradable emissions allowances are transferable allowances relating to the making of emissions of greenhouse gases, allocated under a system for implementing any European Community obligation of the UK in relation to such emissions.

Transferable units issued pursuant to the Kyoto Protocol include assigned amount units, certified emission reductions, emission reduction units and removal units.

To qualify for admission under regulation 11, the transaction must not otherwise fall within any other regulation of the Regulations and must not be a transaction giving rise to either:

  • A chargeable gain falling within TCGA92/S10; or
  • A chargeable gain falling within TCGA92/S10B.