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HMRC internal manual

Offshore Funds Manual

HM Revenue & Customs
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Investors in non-reporting funds: charge to tax on disposal of an interest: the charge to tax: income tax - Regulation 18

Participants within the charge to income tax

Offshore income gains are charged to tax as miscellaneous income under Chapter 8 of Part 5 of ITTOIA 2005 for the year of assessment in which the disposal is made, but sections 688(1) and 689 of ITTOIA do not apply (regulation 18(3)).