Taxation of Chargeable Gains Act 1992 section 103DB

UK property rich collective investment vehicles etc.

Section 103DB introduces Schedule 5AAA, which establishes the tax rules for collective investment vehicles whose assets consist of, or include, direct or indirect interests in UK land.

  • This section serves as the gateway provision introducing Schedule 5AAA to the Taxation of Chargeable Gains Act 1992.
  • Schedule 5AAA targets collective investment vehicles โ€” such as funds and similar pooled investment structures โ€” that hold UK land or property interests.
  • The rules apply whether the vehicle holds UK land directly or indirectly (for example, through shares in a property-holding company).
  • The provision was introduced by the Finance Act 2019, reflecting the government's aim to ensure non-UK residents investing through collective vehicles are brought within the charge to UK capital gains tax on UK property disposals.

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