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HMRC internal manual

Offshore Funds Manual

Investors in non-reporting funds: disposals of interests: exchanging interests in one fund or share class for another

In certain circumstances TCGA provides that exchanges of one type of interest for another will not constitute a disposal and acquisition.

Those provisions of TCGA are not applicable in some circumstances in the case of exchanges involving interests in non-reporting offshore funds as described in the pages referenced below:

  • Exchange of securities for those in another company - OFM14400 
  • Schemes of reconstruction - OFM14500 
  • Exchange of interests of different classes - OFM14600