CFM14005 - Collective investment schemes AIFs: forex

AIFs: AUTs and OEICs: forex

This guidance describes the post FA 2002 provisions for the taxation of loan relationships, derivative contracts and forex.

Authorised Unit Trusts (AUTs) are treated as UK resident companies for corporation tax purposes. Special taxation rules apply to AUTs and open-ended Investment companies (OEICs), which are UK resident companies.. For both, gains are not chargeable gains for corporation tax (TCGA92/S100 (1)).

For accounting periods starting on or after 1 October 2002 the exchange gains and losses of UK resident companies are taxed in accordance with the loan relationship rules (see CFM9000 et seq.)

There are no special rules for the computation of the exchange gains and losses of AUTs and OEICs. However, to preserve the exemption on capital, in bringing these gains and losses into charge to corporation tax the same exclusions apply as if they were profits, gains and losses of loan relationships. (see CFM14002)

Please contact CT & VAT Technical where advice is needed on the pre-FA 2002 rules.