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HMRC internal manual

Offshore Funds Manual

Investors in non-reporting funds: charge to tax on disposal of an interest: the charge to tax: corporation tax - Regulation 18

Participant within the charge to corporation tax

Offshore income gains are charged to tax as miscellaneous income under Chapter 8 of Part 10 of CTA 2009, for the accounting period in which the disposal is made (regulation 18(4)).