The Offshore Funds (Tax) Regulations 2009

[F1Exchanges and schemes of reconstructionU.K.
This section has no associated Explanatory Memorandum

36A.(1) The following sections of TCGA 1992 do not apply to the extent that an interest in a non-reporting fund is exchanged or treated as exchanged for an asset which is not an interest in a non-reporting fund.

(2) The sections are—

(a)section 103G (exchange of units for those in another collective investment scheme),

(b)section 103H (scheme of reconstruction involving issue of units),

(c)section 135 (exchange of securities for those in another company), and

(d)section 136 (scheme of reconstruction involving issue of securities).

(3) In a case where one of those sections would apply apart from paragraph (1), the exchange or deemed exchange shall for the purposes of this Part constitute a disposal of interests in the non-reporting fund for a consideration equal to their market value at the time of the exchange or deemed exchange.]