Corporation Tax Act 2010 section 619

Umbrella schemes

Section 619 defines what an "umbrella scheme" is and explains how each sub-fund within such a scheme is treated as a separate authorised unit trust for corporation tax purposes.

• An umbrella scheme is a unit trust scheme divided into separate sub-funds (pools), each with its own pooling arrangements for contributions and profits, where participants can switch their rights between pools, and which operates under an order made pursuant to section 243 of the Financial Services and Markets Act 2000.
• Each separate sub-fund (part) of an umbrella scheme is treated as an individual authorised unit trust in its own right, while the umbrella scheme taken as a whole is not treated as an authorised unit trust.
• When referring to the investments held on trust within a particular part of an umbrella scheme, only those investments that belong to the relevant separate pool are included — not the assets of the umbrella scheme as a whole.
• A "unit holder" in relation to a particular part of an umbrella scheme means any person who currently holds rights in that specific separate pool, rather than in the umbrella scheme generally.