The NRCGT rules charging gains on disposals by non-UK residents of direct or indirect interests in UK land are modified in the case of collective investment vehicles (CIVs) and their investors so as to limit the potential for multiple layers of UK taxation and any unintended consequences of the rules for exempt investors in offshore pension funds and similar vehicles. For an overview of the NRCGT rules generally see C2.1139 and for an overview of the CIV rules see C2.1160. This article discusses key definitions for the CIV rules.
Meaning of collective investment vehicle
For the purposes of CIV rules in TCGA 1992, Sch 5AAA, a collective investment vehicle means1:
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•ÌýÌýÌýÌý a collective investment scheme (CIS) as defined in FSMA 2000, s 235
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•ÌýÌýÌýÌý an Alternative Investment Fund (AIF) as defined in SI 2013/1773, reg 3
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•ÌýÌýÌýÌý a company which is a UK real estate investment trust (REIT) under CTA 2010, Pt 12 or (from 10 April 2020) is the principal company of a group UK REIT
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