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HMRC internal manual

Offshore Funds Manual

Introduction: overview of the 2009 offshore funds regime: commencement

The 2009 regime has effect for the purposes of -

  • income tax for the tax year 2009-10 and subsequent tax years, and for distributions made on or after 1st December 2009; and
  • for the purposes of corporation tax on income, for accounting periods ending on or after 1st December 2009,

There are some transitional rules for offshore funds relating to periods of account straddling 1 December 2009 and immediately thereafter - see OFM02500.

Once a fund that existed prior to the operative date of the 2009 regime becomes a reporting (or non-reporting) fund, then the new rules apply as explained in the overview at OFM02300 and in the detailed guidance set out later in this manual. Again, transitional rules may apply - see OFM02500