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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. 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. This article discusses the form of rebasing of direct or indirect interests in UK land held within an exempt fund structure in certain cases. Those cases are¹:

1. Ìý

   •ÌýÌýÌýÌý where a right or interest in a company is disposed of by a qualifying fund or qualifying company, or a company owned by a qualifying fund or company, and the assets being rebased have been covered by an exemption election (whether wholly or partially) for a period of 12 months prior to disposal, or

2. Ìý

   •ÌýÌýÌýÌý where a qualifying fund or qualifying