IFM16120 - Exchanges, Mergers, Schemes of Reconstruction: Collective investment schemes

Section 103E Taxation of Chargeable Gains Act 1992 (TCGA)

Chapter 4 of Part 3 of TCGA applies to arrangements involving the following types of CIS:

• An authorised contractual scheme.
• An authorised unit trust (AUT).
• An unauthorised unit trust.
• An offshore fund.
• An open-ended investment company (OEIC).

OEICs are not in the list in S103E, but they are implicitly included with AUTs by virtue of regulation 98 of SI 2006/964.

Where any one of the funds involved in a merger or reconstruction is not such a CIS, Chapter 4 does not apply: see IFM16130.