Damian

Hi, I have a question about Capital Gains Tax and collective fund investments– more specifically, switching funds between Income and Accumulation Units within the same sub-fund / shareclass. I understand that when a fund manager merges funds or undertakes a 'shareclass conversion' to exchange one type of unit for another (e.g., Investment A Acc units to Investment A Inc units) then the base cost for CGT purposes carries over and it is not a 'CGT event'. However, it is unclear as to whether an investor personally switching 100% out of Investment A Acc units and into 100% Investment A Inc units would be liable for capital gains. TCGA 1992 Section 103F leans on the work 'exchanges' but it is unclear whether this is meant to be taken in the literal sense (i.e., the investment manager needs to organise a 'swap' from Acc to Inc) or if investor-triggered switches are also acceptable. HMRC Tax Bulletin 28 seems to specifically imply that investor-led switches are acceptable and would not crystallise a gain; similarly, CG57709 uses the word 'switch' when referring to moving between Accumulation and Income units. Could you please confirm either way. Thanks.