Certain offshore collective investment vehicles (CIVs) can elect to be exempt from corporation tax on chargeable gains accruing on direct and indirect disposals of UK land under the NRCGT regime. For an overview of the NRCGT rules generally see C2.1139 and for an overview of the CIV rules see C2.1160. See C2.1165 for further detail on the exemption election. It is possible for a gain or loss on a disposal to be, in principle, exempted under both the exemption election and under other capital gains exemptions including the substantial shareholding exemption and the exemption for disposals by UK real estate investment trusts (REITs).
Where the rules both apply, there are provisions that provide which exemption has priority and also how the different exemptions are to be calculated generally.
Interaction with the substantial shareholding exemption
The CIV exemption election and substantial shareholding exemptions (see Division D1.10) can interact in the case of a company (the investing
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