IFM13220 - Offshore Funds: participants in offshore funds: participants within the charge to corporation tax: reporting funds

Regulation 98 of SI 2009/3001

Corporate investors in offshore funds will be chargeable to corporation tax on any distributions received from reporting funds under general principles, and on any excess of reported income of the fund invested in under regulation 94(1) and (2).

Where such investors are taxable under regulation 94(1) on excess reported income, that amount will be treated as exempt if it would be exempt had it been an actual distribution.

The bond fund rules in Chapter 3 of Part 6 CTA 2009 may apply if a reporting fund held more that 60% by value of its investments in debt type assets at any time during an investing company’s accounting period - see the Corporate Finance Manual.