Taxes Consolidation Act 1997 Schedule 19 paragraph 9

Primary fund's proportionate share of a qualifying fund's assets

Paragraph 9 of Schedule 19 sets out how to calculate the primary fund's proportionate share of a qualifying fund's assets or excess income for the purposes of paragraphs 7 and 8.

• Where a primary fund holds an interest in a qualifying (second-tier) fund, its share of that fund's assets or excess income must be determined on a proportionate basis.
• The proportion is calculated as C ÷ D, where C is the average value of the primary fund's holding in the qualifying fund during the account period, and D is the average value of all interests in the qualifying fund held by any persons during that period.
• Both the numerator and denominator are measured as averages over the relevant account period of the primary fund.
• The resulting fraction is then applied to the qualifying fund's relevant interest or excess income when computing the primary fund's deemed holdings under paragraphs 7 and 8.