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HMRC internal manual

Company Taxation Manual

Authorised investment funds: collective investment schemes: general: offshore funds

Meaning of offshore fund – section 756A ICTA 1988

Offshore funds are collective investment schemes based outside the UK, whether constituted as a company resident outside the UK, as a unit trust scheme with trustees resident outside the UK or by any other arrangements under the law of a territory outside the UK which, under that law, result in co-ownership.

For details of the taxation of UK residents holding rights in offshore funds please see IM4075 onwards and legislation at ICTA88/S765A.