IFM08630 - Co-ownership Authorised Contractual Schemes (CoACS): Chargeable Gains: part-disposals
If amounts which are not income are paid out of a CoACS or offshore transparent fund the normal chargeable gains rules will treat this as a part-disposal of the holding of units: there may be a liability to tax on any gain accruing at that stage. See section 22 of the Taxation of Chargeable Gains Act 1992 and HMRC바카라 사이트™s guidance at CG12940P.
It is unlikely that such a part-disposal would arise in relation to a CoACS as a result of regulatory restrictions: amounts which are not income are unlikely to be paid out when there is no disposal of units. However, a part-disposal may occur in relation to an offshore transparent fund.
Amounts paid out of a CoACS which do not constitute a part-disposal of the holding of units should be treated as a reduction in expenditure - see IFM08620.