PART 3Non-exempt unauthorised unit trusts

CHAPTER 2Tax treatment of non-exempt unauthorised unit trusts

Non-exempt unauthorised unit trust treated as UK resident company28.

(1)

In respect of income arising and chargeable gains accruing to UK resident trustees of a non-exempt unauthorised unit trust, and for the purposes of the provisions relating to relief for capital expenditure, the Tax Acts have effect as if—

(a)

the trustees were a UK resident company, and

(b)

the rights of the unit holders were shares in the company.

(2)

References in the Corporation Tax Acts to a body corporate are to be read in accordance with paragraph (1); and sections 1104 and 1107 of CTA 2010 (companies and nominees required to provide tax certificates) apply with any necessary modifications.