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Textual Amendments
F1Sch. 5AAA inserted (with effect in accordance with Sch. 1 paras. 120, 123 of the amending Act) by Finance Act 2019 (c. 1), Sch. 1 para. 21
21(1)This paragraph applies if—U.K.
(a)an election under paragraph 12 that has been made in respect of a qualifying fund or qualifying company has effect at any time,
(b)a participant in the relevant fund is entitled to receive an amount at that time (“the relevant time”) which represents, in substance, value derived (directly or indirectly) from a direct disposal of UK land or from the UK land component of an indirect disposal of UK land, and
(c)the amount is regarded as being of a revenue nature and does not fall to be taken into account for the purposes of income tax or corporation tax on income.
(2)In the case of an election made in respect of a qualifying fund, the participant in the relevant fund is deemed for the purposes of this Act—
(a)to have sold its units in the relevant fund immediately before the relevant time at their market value immediately before that time, and
(b)to have reacquired those units immediately after the relevant time at their market value immediately after that time.
(3)In the case of an election made in respect of a qualifying company, the participant in the relevant fund is deemed for the purposes of this Act—
(a)to have sold its rights and interests in the company immediately before the relevant time at their market value immediately before that time, and
(b)to have reacquired those rights and interests immediately after the relevant time at their market value immediately after that time.
(4)In this paragraph “the UK land component” of an indirect disposal of UK land means the interests in UK land taken into account in determining whether the disposal is an indirect disposal of UK land.]