Taxation of Chargeable Gains Act 1992 Schedule 5AAA paragraph 9

Further provision about election

Section 9 sets out the conditions, time limits, and information requirements that must be met when an offshore collective investment vehicle elects to be treated as a partnership for UK capital gains tax purposes.

• All participants in the vehicle must consent to the election, which must be notified to HMRC within 12 months of the date the vehicle first acquires an interest in UK land or a UK property-rich company.
• The relevant acquisition date is the earliest date on which UK land or an interest in a UK property-rich company forms part of the vehicle's property.
• Once made, the election is irrevocable and cannot be withdrawn or reversed.
• The election must include specified details for each participant, including their name, unique taxpayer reference (if any), address, and date of birth (for individuals).