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HMRC internal manual

Offshore Funds Manual

Investors in non-reporting funds: income & distributions: the charge to tax: remittance basis

Where an investor in a (non-transparent) non-reporting offshore fund is taxed on the remittance basis then the remittance basis rules apply to income arising from the holding in that fund as they apply to other income from non-UK sources.

Where the fund is transparent for tax-purposes, then the income will arise from the underlying assets and not from the fund. In such a case the income may sometimes arise in the UK (even though the fund itself is domiciled offshore). Where the income arises in the UK the remittance basis does not apply. Where the income arises offshore then the remittance rules will apply.

Disposals of interests in non-reporting funds by remittance basis investors

See OFM15500.