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Section 103F: Exchanges of units for units in the same scheme

Taxation of Chargeable Gains Act 1992 · 1992 c. 12View on legislation.gov.uk

Part III: Individuals, partnerships, trusts and collective investment schemes etc — Chapter 4: Collective investment schemes: exchanges, mergers and schemes of reconstruction

This section applies in the following cases.

  • Case 1 Where—

    (a)a participant in a collective investment scheme exchanges units in the scheme for other units in the scheme ("new units") of substantially the same value, and

    (b)the property subject to the scheme and the rights of participants to share in the capital and income in relation to that property are the same immediately before and immediately after the event (ignoring any changes as a result of a variation in management charges).

  • Case 2 Where there is a reorganisation of the units in a collective investment scheme in which all the participants holding units in the scheme or, where there are different classes of unit in the scheme, all the participants holding units in the same class, exchange all their units for other units ("new units") in the scheme.

Where this section applies—

sections 127 to 131 (share reorganisations etc) apply with the necessary adaptations as if the collective investment scheme were a company and the event mentioned in subsection (1) were a reorganisation of its share capital, and
any distribution in relation to any new units is to be treated for the purposes of capital gains tax, corporation tax or income tax on the basis set out in section 127 (as adapted).

In subsection (1), "management charges" mean the costs charged to the property subject to the scheme in respect of remunerating the parties operating the scheme, administrating the scheme or investing or safeguarding the property subject to the scheme.

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This legislation text comes from legislation.gov.uk. Contains public sector information licensed under the Open Government Licence v3.0. These source and reuse terms cover the legislation text, not Remedy's commentary.

Reuse reviewed 21 August 2026 under Open Government Licence v3.0.