IFM12000 - Offshore funds: introduction and contents

This part of the Investment Funds Manual explains how UK resident investors in offshore funds are treated for tax purposes. It sets out the background to the offshore funds tax regime that applied to UK investors in offshore funds from 1984 to 2009 and provides detailed guidance explaining how UK investors are treated under the current regime now at Part 8 of the Taxation (International and Other Provisions) Act 2010 and the Offshore Funds (Tax) Regulations 2009 (SI 2009/3001) as subsequently amended.

1. IFM12100

   Introduction: background to the treatment of UK investors in offshore funds
2. IFM12200

   Offshore Funds: Definition of an offshore fund: overview
3. IFM12220

   Offshore Funds: Definition of an offshore fund: Meaning of ‘offshore fund’
4. IFM12230

   Offshore Funds: Definition of an offshore fund: Meaning of ‘mutual fund’
5. IFM12240

   Offshore Funds: Definition of an offshore fund: exceptions to the meaning of mutual fund
6. IFM12250

   Transparent entities
7. IFM12260

   Umbrella funds and protected cell companies
8. IFM12270

   Classes of interest
9. IFM12280

   Definition of an offshore fund: particular arrangements
10. IFM12300

    Offshore Funds: introduction: non-reporting funds
11. IFM12400

    Offshore Funds: Reporting Funds
12. IFM12500

    Offshore Funds: Reporting funds: computation of reportable income
13. IFM12600

    Offshore Funds: Reporting funds: reporting obligations
14. IFM12700

    Offshore Funds: Reporting funds: breaches of reporting fund conditions
15. IFM12800

    Offshore Funds: Reporting funds: leaving the regime