Trustees' gains - offshore income gains
Offshore income gains are taxed as income, SI 2009/3001 regulation 18. Therefore any offshore income gain arising to the trustees’ is not included in the trustees’ section 2(2) amount. A loss on the disposal of an interest in a non-reporting fund is available to the trustees as a capital loss because losses are not deductible in calculating offshore income gains, SI 2009/3001 regulation 42. See the Offshore Funds Manual for guidance on offshore income gains.