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HMRC internal manual

Offshore Funds Manual

From
HM Revenue & Customs
Updated
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Investors in non-reporting funds: computation of offshore income gains: introduction - Regulation 38

An offshore income gain (‘OIG’) will arise when a UK investor disposes of an interest in -

  • a non-reporting fund;
  • a reporting fund that has not had reporting fund status for the entire period during which the investor held their interest (and in respect of which no election was made under paragraph (4) of Schedule 1 to the Offshore Funds (Tax) Regulations 2009) at the appropriate time (see OFM19000); or
  • a reporting fund which was previously a non-qualifying fund (i.e. one that did not have distributing fund status) for any part of period during which the investor held their interest (and in respect of which no election was made under paragraph (4) of Schedule 1 to the Offshore Funds (Tax) Regulations 2009 at the appropriate time),

and a ‘basic gain’ arises on such a disposal.

The OIG will be an amount equal to the basic gain. The following pages explain that term, and the more detailed provisions that apply to such disposals.