Closed consultation

Residence of Offshore Funds - extending the scope of Section 363A Taxation Act 2010

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Original consultation

This consultation ran from to

Summary

The Government announced at Budget 2013 that it would consult on proposals to widen the scope of section 363A TIOPA. HM Revenue & Customs (HMRC) are asking for views on the scope of the extension.

Documents

Residence of Offshore Funds - extending the scope of Section 363A Taxation (International and Other Provisions) Act 2010

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Consultation description

Section 363A Taxation (International and Other Provisions) Act 2010 (‘TIOPA’) treats certain offshore funds as not resident in the UK if they are resident under the law of a Member State.

HMRC would like to hear in particular from tax practitioners, fund managers, representative bodies, administrators and other interested parties.