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HMRC internal manual

Offshore Funds Manual

Investors in non-reporting funds: exceptions to the charge to tax: registered pension schemes - Section 186 Finance Act 2004

If a UK registered pension scheme (within the meaning of section 153 FA 2004) disposes of an interest in a non-reporting fund, any gain arising will be exempt from the charge to tax under regulation 17.

Similarly, S186(1)(a) Finance Act 2004 would have the effect that an offshore income gain would not be chargeable on a pension fund if it were attributed under regulation 24.