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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. Certain offshore CIVs can elect to be exempt from corporation tax on chargeable gains accruing on direct and indirect disposals of UK land; see C2.1165. Where an election has been made, In certain situations, a deemed disposal of each of the investors' interests in the qualifying fund or qualifying company (see C2.1165) will occur. The situations are:

1. Ìý

   (a)ÌýÌýÌýÌý where an exemption election ceases to have effect because the applicable conditions are no longer met (except for cases where the failure is temporary and lasts no longer than 30 days, see C2.1168)¹