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HMRC internal manual

Offshore Funds Manual

Investors in non-reporting funds: exceptions to the charge to tax: rights arising under a policy of insurance - Regulation 25(6)

Where an interest in an offshore fund would fall to be treated as rights under a policy of insurance, any gain arising on disposal will not be taxed as an offshore income gain.

Guidance on the tax treatment of policy holders can be found in the Insurance Policyholder Taxation Manual (IPTM) .