The Co-ownership Contractual Schemes (Tax) Regulations 2025

Exemptions for disposals by companies with substantial shareholding

54.—(1) Schedule 7AC to TCGA 1992(1) is amended as follows.

(2) In paragraph 3B (subsidiary exemption: qualifying institutional investors)—

(a) in sub-paragraph (4)(b)—

(i) the words from the first “as” to the end become sub-paragraph (i), and

(ii) after that sub-paragraph insert—

“(ii) as including an exempt Reserved Investor Fund (Contractual Scheme) (and references to ordinary share capital, in the case of such a scheme, as references to units in the scheme).”;

(b) after sub-paragraph (6) insert—

“(6A) Sub-paragraph (6) does not apply in relation to a co-ownership scheme which is treated as a partnership under section 103DC (co-ownership schemes which are to be treated as partnerships).”;

(c) for sub-paragraph (7), substitute—

“(7) In this Schedule—

“exempt Reserved Investor Fund (Contractual Scheme)” means a Reserved Investor Fund (Contractual Scheme) which meets the exempt investor condition in regulation 14 of the Co-ownership Contractual Schemes (Tax) Regulations 2025;

“exempt unauthorised unit trust” has the same meaning as in regulation 3 of the Unauthorised Unit Trusts (Tax) Regulations 2013 (2).”.

(3) In paragraph 30A(1) (meaning of qualifying institutional investor), at the end insert—

“(H) Exempt Reserved Investor Fund (Contractual Scheme)

Exempt Reserved Investor Fund (Contractual Scheme) (within the meaning given by paragraph 3B(7)).”.

(1)

Schedule 7AC was inserted by paragraph 1 of Schedule 8 to the Finance Act 2002 (c. 23). Paragraphs 3A, 3B and 30A of Schedule 7AC were inserted by section 28 of the Finance (No. 2) Act 2017 (c. 32).

(2)

S.I. 2013/2819.