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Change 1
As published
41 Non-residents: double taxation relief relating to collective investment vehicles
(1) In paragraph 2 of Schedule 18 to FA 1998 (duty to give notice of chargeability to corporation tax), after sub-paragraph (2) insert—
(2A) Where sub-paragraph (1A) would apply as regards a company if the company were to make a claim to obtain relief under section 6(2)(a) or (3)(a) of TIOPA 2010 in respect of a disposal that has an appropriate connection to a collective investment vehicle for the purposes of paragraph 6 of Schedule 5AAA to TCGA 1992, the company is not required to make such a claim in order to obtain relief in respect of the disposal (despite section 6(6) of TIOPA 2010).
(2) In section 55A of FA 2004 (exception to duty to give notice to coming within charge to corporation tax), after subsection (4) insert—
(5) Where subsection (1) would apply as regards a company if the company were to make a claim to obtain relief under section 6(2)(a) or (3)(a) of TIOPA 2010 in respect of a disposal that has an appropriate connection to a collective investment vehicle for the purposes of paragraph 6 of Schedule 5AAA to TCGA 1992, the company is not required to make such a claim in order to obtain relief in respect of the disposal (despite section 6(6) of TIOPA 2010).
(3) In Schedule 2 to FA 2019—
(a) in the heading before paragraph 10 (no return required in respect of disposal connected to CIS), for “schemes” substitute “vehicles”;
(b) in paragraph 10—
(i) for “scheme” substitute “vehicle”;
(ii) after sub-paragraph (2) insert—
(3) If, by virtue of sub-paragraph (1), a person is not required to make or deliver a return under this Schedule in respect of a disposal, the person is not required to make a claim to obtain relief under section 6(2)(a) or (3)(a) of TIOPA 2010 in respect of the disposal (despite subsection (6) of that section).
;
(c) in paragraph 11(1)(a)—
(i) for “CIS” substitute “CIV”;
(ii) for “scheme” substitute “vehicle”;
(d) in paragraph 11(1)(b), for “subject of the scheme” substitute “subject of or held by the vehicle”;
(e) in paragraph 12(1)(a), for “CIS” substitute “CIV”.
(4) The amendments made by subsections (1) and (2) have effect in relation to disposals made on or after 1 April 2026.
(5) The amendments made by subsection (3) have effect in relation to disposals made on or after 6 April 2026.
Your change, as a redline
41 Non-residents: double taxation relief relating to collective investment vehicles
(1) In paragraph 2 of Schedule 18 to FA 1998 (duty to give notice of chargeability to corporation tax), after sub-paragraph (2) insert—
(2A) Where sub-paragraph (1A) would apply as regards a company if the company were to make a claim to obtain relief under section 6(2)(a) or (3)(a) of TIOPA 2010 in respect of a disposal that has an appropriate connection to a collective investment vehicle for the purposes of paragraph 6 of Schedule 5AAA to TCGA 1992, the company is not required to make such a claim in order to obtain relief in respect of the disposal (despite section 6(6) of TIOPA 2010).
(2) In section 55A of FA 2004 (exception to duty to give notice to coming within charge to corporation tax), after subsection (4) insert—
(5) Where subsection (1) would apply as regards a company if the company were to make a claim to obtain relief under section 6(2)(a) or (3)(a) of TIOPA 2010 in respect of a disposal that has an appropriate connection to a collective investment vehicle for the purposes of paragraph 6 of Schedule 5AAA to TCGA 1992, the company is not required to make such a claim in order to obtain relief in respect of the disposal (despite section 6(6) of TIOPA 2010).
(3) In Schedule 2 to FA 2019—
(a) in the heading before paragraph 10 (no return required in respect of disposal connected to CIS), for “schemes” substitute “vehicles”;
(b) in paragraph 10—
(i) for “scheme” substitute “vehicle”;
(ii) after sub-paragraph (2) insert—
(3) If, by virtue of sub-paragraph (1), a person is not required to make or deliver a return under this Schedule in respect of a disposal, the person is not required to make a claim to obtain relief under section 6(2)(a) or (3)(a) of TIOPA 2010 in respect of the disposal (despite subsection (6) of that section).
;
(c) in paragraph 11(1)(a)—
(i) for “CIS” substitute “CIV”;
(ii) for “scheme” substitute “vehicle”;
(d) in paragraph 11(1)(b), for “subject of the scheme” substitute “subject of or held by the vehicle”;
(e) in paragraph 12(1)(a), for “CIS” substitute “CIV”.
(4) The amendments made by subsections (1) and (2) have effect in relation to disposals made on or after 1 April 2026.
(5) The amendments made by subsection (3) have effect in relation to disposals made on or after 6 April 2026.
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