Taxation of Chargeable Gains Act 1992 Schedule 5AZA paragraph 6

Subsequent issue of units to be disregarded

Paragraph 6 of Schedule 5AZA provides that later issues of units in a successor scheme or feeder fund, made after the initial transfer of property is complete, are to be ignored when testing whether the first and second conditions for a qualifying scheme of reconstruction are met.

• This rule applies to units issued in any successor collective investment scheme or feeder fund after the property transfer is complete.
• The cut-off point is the latest date on which units are issued in exchange for property becoming subject to the successor scheme under the reconstruction arrangements.
• Any units issued after that cut-off date are disregarded when assessing the first and second conditions for a qualifying reconstruction.
• The purpose is to ensure that routine subsequent unit issues (such as those to new investors) do not disturb the tax treatment of the original reconstruction.