The Open-ended Investment Companies (Tax) Regulations 1997

Ownership of shares in open-ended investment companies

24.—(1) Where, in respect of a given class of shares specified in the instrument of incorporation of an open-ended investment company, shares issued of that class consist of both smaller denomination shares and larger denomination shares, and a person owns both smaller denomination shares and larger denomination shares of that class—

(a)those shares owned by him shall be treated as being securities of the same class for the purposes of the provisions of the Tax Acts and the 1992 Act relating to ownership of shares in a company,

(b)each larger denomination share shall be treated for those purposes as if it were comprised of the relevant number of smaller denomination shares, and

(c)the market value of each smaller denomination share shall be taken for those purposes to be the relevant proportion of the market value of each larger denomination share.

(2) In paragraph (1)—

(a)“smaller denomination shares” means shares to which are attached rights specified in the company’s instrument of incorporation that are expressed in the smaller of two denominations, and “larger denomination shares” means shares to which are attached rights so specified that are expressed in the larger of two denominations;

(b)“relevant number” means the number calculated by reference to the relevant proportion;

(c)“relevant proportion” means the proportion, determined by the company’s instrument of incorporation, which the rights attaching to each smaller denomination share bear to the rights attaching to each larger denomination share.