Corporation Tax Act 2010 section 622

Treatment of capital expenditure

Section 622 establishes that capital allowances and charges arising from capital expenditure within a unit trust scheme are attributed to the trustees, not to the individual unit holders.

• Capital allowances and charges under capital expenditure rules apply at the trustee level of a unit trust scheme.
• Individual unit holders do not directly receive or bear any capital allowances or charges relating to the trust's capital expenditure.
• The trustees are treated as the relevant persons for the purposes of all capital expenditure provisions.
• This rule ensures a clear separation between the tax treatment of capital expenditure at the trust level and the tax position of unit holders.