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HMRC internal manual

Offshore Funds Manual

HM Revenue & Customs
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Investors in non-reporting funds: exceptions to the charge to tax: long-term insurance funds - Regulation 27

Where an interest in an offshore fund that is an asset of an insurance company’s long-term insurance fund is disposed of, any gain arising on disposal will not be taxed as an offshore income gain.

In this context, ‘insurance company’ and ‘long-term insurance fund’ have the same meaning as in section 431(2) of ICTA. A long-term insurance fund is, broadly, the funds that an insurance company maintains to meet its long term liabilities, such as payments to annuitants.