747FA Offshore funds: amalgamations with investment undertakings

Summary

This section was inserted by section 33 of the Finance Act 2012 and is consequent on the implementation of the UCITS IV Directive, which provides for the cross-border merger of two or more UCITS funds.

Details

Definitions

(1) Subsection (1) sets out how the term “investment undertaking” is to be interpreted. The subsection also provides a definition for “scheme of amalgamation”.

(2) In the context of a scheme of amalgamation, the disposal of a material interest in an offshore fund and the acquisition of units in an investment undertaking, will not give rise to a chargeable event. On the occurrence of future chargeable events, the date and cost of the units will be the same date and cost as the original material interest in the offshore fund.

Relevant Date: Finance Act 2019