CG41580 - Open-ended investment companies (OEICs): umbrella OEICs
An umbrella OEIC is an OEIC which is split into a number of separately pooled funds ofassets, known as the sub-funds (or parts) of the umbrella company. This definition is atICTA88/S468A (4) and is adopted for the purposes of the OEICs tax regime by SI2006/964regulation 7. Regulation 106 imports the same definition into TCGA 1992 by inserting a newsection 99AA into that Act.
An umbrella OEIC is not treated as a company for tax purposes. It is entirely transparent.Each separate sub-fund of the umbrella company is instead regarded as an OEIC in its ownright, with the assets which relate to that pool of investments constituting the deemedOEIC바카라 사이트™s assets (except where the context requires otherwise).
A holder of shares in the umbrella company is deemed to be the owner of shares in thedeemed OEIC which is the sub-fund in which the holder has rights for the time being. Thoserights can be exchanged for rights in another sub-fund of the umbrella company, seeCG57760.
Such an exchange will represent a disposal and a separate acquisition for TCGA purposesand so may give rise to a chargeable gain or loss.
This approach to umbrella companies and their parts did not change when SI2006/964 cameinto force.