Legislation – Finance Act 2026
Part 1Income tax, capital gains tax and corporate taxes
Chargeable gains
41Non-residents: double taxation relief relating to collective investment vehicles
(1)
“(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)
“(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)
“(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.