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HMRC internal manual

Offshore Funds Manual

Investors in non-reporting funds: exceptions to the charge to tax: intangible fixed assets - Regulation 25(4)

Where a company has a holding in an offshore fund and that holding would be subject to the tax rules relating to intangible fixed assets as set out in Part 8 of CTA 2009, then for so long as that is the case the holding will be subject to the intangible fixed asset rules.

Those rules contain their own detailed provisions relating to holdings of such assets, and where they apply then any gain on disposal of such an asset will not be treated as an offshore income gain.

Detailed guidance on the treatment of intangible fixed assets can be found in the Corporate Intangibles Research & Development Manual (CIRD).