I have acquired (via a legacy) some fund accumulation ("ACC") units outside of a SIPP or ISA wrapper. I'd like to convert them to income yielding ("INC") units in the same fund. There are now significant capital gains on those units since the inheritance "reset" the book value so simply selling the ACC units to repurchase INC units of the same fund would seem to have me paying some tax (which obviously I'd prefer to minimise).
However, my understanding is that under the capital gains tax rules on "section 104 holdings", "bed and breakfasting" and "matching" (see here or here), if I repurchase units in the same fund in the "same class" within 30 days then any gain (or loss due) is just calculated relative to the sale price, and the book cost remains unaffected.
My question is: do "ACC" and "INC" units in the same fund (and in the same "class A"/"class D"/"class R" units) count as being in the "same class" so far as HMRC are concerned? So if I sold the ACC units and immediately (next day) reinvested all the proceeds in INC units would there be any CGT liability triggered or would I simply now have a holding of INC units with the same original book value as the ACC units did?