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Disposals on or after 1 January 2018

For disposals on or after 1 January 2018 the rules applying to the calculation of chargeable gains on offshore transparent funds¹ have been brought in line with those applying to authorised contractual schemes which are co-ownership schemes (see D8.146)² For disposals from that date a unit in such a fund is treated as an asset, and therefore a participant's interest in the fund property is disregarded for these purposes. The chargeable gains computation on disposal should take account of expenditure incurred under the old rules up to 31 December 2017 and under the revised rules from 1 January 2018³.

In calculating the gain, income from the fund which is taken into account as a receipt or other credit of the participant in calculating an amount chargeable to income tax is to be treated as enhancement expenditure under TCGA 1992, s 38(1)(b) (see C2.206)⁴. However, any deductions under TCGA 1992, s 38(1) must be reduced by any amount arising to the participant