615Umbrella companiesU.K.
(1)In this section “umbrella company” means an open-ended investment company—
(a)whose instrument of incorporation provides arrangements for separate pooling of the contributions of the shareholders and the profits or income out of which payments are made to them, and
(b)whose shareholders are entitled to exchange rights in one pool for rights in another.
(2)References in this section to a part of an umbrella company are to a separate pool.
(3)For the purposes of this Chapter—
(a)each of the parts of an umbrella company is to be regarded as an open-ended investment company, and
(b)the umbrella company as a whole is not to be regarded as an open-ended investment company.
(4)The umbrella company as a whole is not to be regarded as a company for any other purpose of the Tax Acts unless an enactment expressly provides otherwise.