IFM09330 - Taxation of investors: Chargeable gains: Umbrella scheme
Regulation 52(2) amends section 99A(6) TCGA 1992 “Treatment of umbrella schemes” so that where a RIF is structured as an ‘umbrella scheme’, participants’ interests in the umbrella scheme are disregarded and each sub-scheme is treated as a separate collective investment scheme for capital gains purposes. Participants are therefore treated as holding units in the sub-scheme and not the umbrella scheme.
For further information regarding how the rules for RIFs generally are adapted for umbrella schemes – see IFM09850.