Taxes Consolidation Act 1997 Schedule 20 paragraph 1

Material disposal

Paragraph 1 defines the term "material disposal" for the purposes of Part 1 of Schedule 20, which contains the rules for computing gains on disposals of interests in non-qualifying offshore funds.

• A material disposal is a disposal that falls within Chapter 2 of Part 27.
• It excludes disposals that are only caught by Chapter 2 because of section 742 (equalisation arrangements).
• In practice, a material disposal is a disposal of a material interest in a non-qualifying (non-distributing) offshore fund.
• Disposals of interests in distributing funds operating equalisation arrangements are covered separately in Part 2 of Schedule 20.