{
  "url": "https://openlegislation.uk/taxation-of-chargeable-gains-act-1992/section-103G",
  "json_url": "https://openlegislation.uk/taxation-of-chargeable-gains-act-1992/section-103G.json",
  "legislation": "ukpga/1992/12",
  "legislation_title": "Taxation of Chargeable Gains Act 1992",
  "legislation_url": "https://openlegislation.uk/taxation-of-chargeable-gains-act-1992",
  "path": "section/103G",
  "kind": "section",
  "number": "103G",
  "heading": "Exchange of units for those in another collective investment scheme",
  "text": "(1) This section applies in the following cases where units in a collective investment scheme (“collective investment scheme B”) are issued to a person in exchange for units in another collective investment scheme (“collective investment scheme A”).\n(2) The cases are—\nCase 1\nWhere units in collective investment scheme B are issued in exchange for units as the result of a general offer—\n(a)made to participants in collective investment scheme A or any class of them, and\n(b)made in the first instance on a condition such that if it were satisfied the property subject to collective investment scheme B would include units in collective investment scheme A giving rights to more than 50% of the capital, and more than 50% of the income, of collective investment scheme A.\nCase 2\nWhere—\n(a)under an arrangement, participants in collective investment scheme A exchange units in that scheme for units of substantially the same value in collective investment scheme B, and\n(b)in consequence of the exchanges under the arrangement, 85% or more of the property subject to collective investment scheme B is constituted by units in collective investment scheme A.\n(3) Where this section applies, sections 127 to 131 (share reorganisations etc) apply with the necessary adaptations as if collective investment scheme A and collective investment scheme B were the same company and the exchange were a reorganisation of its share capital.\n(4) This section has effect subject to section 103K (anti-avoidance).",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 3 Ch. 4 inserted (8.6.2013) by The Collective Investment Schemes (Tax Transparent Funds, Exchanges, Mergers and Schemes of Reconstruction) Regulations 2013 (S.I. 2013/1400), regs. 1(1), 11 (with reg. 1(2))"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Words in s. 103G(4) substituted (with effect in accordance with s. 36(6) of the amending Act) by Finance Act 2026 (c. 11), s. 36(2)(6) (with s. 36(7))"
    },
    {
      "type": "C",
      "label": "C1",
      "text": "S. 103G excluded by Offshore Funds (Tax) Regulation 2009 (S.I. 2009/3001), reg. 36A(2)(a) (as substituted (8.6.2013) by S.I. 2013/1400, regs. 1(1), 15(a) (with reg. 1(2)))"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/1992/12/section/103G",
    "retrieved_at": "2026-10-29T09:36:15.270072+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}