Taxation of Chargeable Gains Act 1992 section 51

Genuine diversity of ownership condition in case of existing funds

Section 51 provides a modified way for collective investment vehicles that were set up before 6 April 2020 to demonstrate that they meet the genuine diversity of ownership condition required elsewhere in the Schedule.

• Applies only to collective investment vehicles constituted before 6 April 2020
• The vehicle's manager must prepare a statement, available to HMRC, confirming intended investor categories, wide availability of interests, and proper marketing
• This statement replaces the standard documentary requirements under the Offshore Funds (Tax) Regulations 2009
• Where the vehicle is part of multi-vehicle arrangements, the same modified approach applies to those arrangements as a whole

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