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HMRC internal manual

Offshore Funds Manual

Investors in non-reporting funds: computation of offshore income gains: losses - Regulation 42

If, in calculating the ‘basic gain’ (under regulations 39 to 41) arising on the disposal of an interest in an offshore fund the result would produce a loss, then the basic gain arising on the disposal is treated as nil. This means that, for the purposes of the regulations, no loss is to be treated as arising on a disposal and that any loss arising can be relieved only as a capital loss.