Taxes Consolidation Act 1997 section 733

Reorganisation of units in unit trust scheme

Section 733 extends the share reorganisation rules to unit trusts, allowing units to be switched between sub-funds within an umbrella unit trust without triggering a capital gains tax disposal.

• A reorganisation of units includes allotments of new units in proportion to existing holdings and changes to the rights attached to any class of units.
• Section 584 (reorganisation or reduction of share capital) applies to reorganisations or reductions of units in registered or authorised unit trust schemes, treating the scheme as a company and the units as shares.
• The section 584 treatment does not apply where the reorganisation would result in units that are exempt from capital gains tax being treated as the original or new holding.
• The references to section 584 do not extend to its application through section 585 (conversion of securities) or section 586 (company amalgamations by exchange of shares).