CG73996T - UK property rich collective investment vehicles: Key definitions and terms: Meaning of 'participant'

Paragraph 1(5) of Schedule 5AAA to Taxation of Chargeable Gains Act 1992 defines a ‘participant’ as

(a) in relation to a collective investment scheme or an AIF, a person who takes part in the arrangements or undertaking constituting the scheme or AIF, whether by becoming the owner of, or of any part of, the property that is the subject of or held by the arrangements or undertaking or otherwise, or

(b) in relation to a company within (1)(c) or (d), a shareholder in the company.

Where a tax transparent entity holds an interest in a UK property rich CIV, the fund participants are the underlying investors of that entity (tracing through, if applicable, a chain of transparent entities). Tax transparent entities include partnerships, or CIVs that have elected for transparency.