Taxation of Chargeable Gains Act 1992 Schedule 5AAA paragraph 2

Meaning of "offshore collective investment vehicle"

Section 2 of Schedule 5AAA defines what constitutes an "offshore collective investment vehicle" for the purposes of the Schedule, covering three types of non-UK investment structures.

• An offshore collective investment vehicle can be a body corporate (excluding limited liability partnerships) that is resident outside the United Kingdom
• It can also be a trust-based vehicle where property is held on trust for participants and the trustees are not UK-resident
• It further includes vehicles constituted by other arrangements creating co-ownership rights, where those arrangements take effect under the law of a territory outside the United Kingdom
• The term "co-ownership" is given a broad meaning and is not restricted to how it is defined in any part of UK law