SCHEDULES
SCHEDULE 22Offshore funds
Part 2Application of TCGA 1992 to offshore funds
Modification of acquisition cost
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1
This paragraph applies where a participant in a relevant offshore fund—
a
holds rights in a relevant offshore fund immediately before the effective date, and
b
disposes of those rights on or after that date.
2
For the purposes of TCGA 1992 the participant is to be treated as if the acquisition cost for those rights were the pre-commencement acquisition cost.
3
“The effective date” means—
a
if the participant has made an election under paragraph 15, the election day, or
b
otherwise, the commencement day.
4
“Acquisition cost” means the total of the consideration, costs and expenditure described in section 38(1)(a) and (b) of TCGA 1992 (acquisition and disposal costs etc).
5
“Pre-commencement acquisition cost” means the total of the consideration, costs and expenditure that would have been allowable as a deduction under section 38(1)(a) and (b) of TCGA 1992 if the participant had disposed of the rights immediately before the effective date.