Taxation of Chargeable Gains Act 1992 section 103DA

Tax transparent funds: share pooling etc

Section 103DA confirms that units held in tax transparent funds are treated as securities for the purposes of the share pooling and identification rules.

• Units in a tax transparent fund are classified as securities under the capital gains share pooling rules.
• This means the standard section 104 pooling provisions apply to such units, averaging the cost of units acquired over time.
• The identification rules that determine which securities are matched to a disposal (including same-day and 30-day matching) also apply to transparent fund units.
• For corporation tax purposes, the indexation allowance and options rules likewise apply to these units in the same way as they do to ordinary shares and securities.