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HMRC internal manual

Offshore Funds Manual

From
HM Revenue & Customs
Updated
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S355 (1)(b) TIOPA 2010

Most mutual funds where the property of the fund is held on trust for the investors by trustees who are resident outside of the United Kingdom will fall within the definition of ‘offshore fund’.

It will usually be the case that offshore trust arrangements will not come within the definition of a mutual fund, but those that do come within the meaning of a mutual fund at S355 (1)(b) TIOPA 2010 will be offshore funds, unless exceptionally the trust is ‘closed-ended’ - that is, it cannot issue or redeem units on request - and it falls within any of the exceptions within S357 TIOPA 2010.

See OFM05000 onwards for guidance regarding the meaning of the term ‘mutual fund’.