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HMRC internal manual

Offshore Funds Manual

From
HM Revenue & Customs
Updated
, see all updates

Reporting funds: tax treatment of participants in reporting funds: participants chargeable to corporation tax - Regulation 98

Corporate investors in offshore funds will be chargeable to corporation tax on any distributions received from reporting funds under general principles, and on any excess of reported income of the fund invested in under regulation 94(1) and (2).

Where such investors are taxable under regulation 94(1) on excess reported income, that amount will be treated as exempt if it would be exempt had it been an actual distribution.

The bond fund rules in Chapter 3 of Part 6 CTA 2009 (relationships treated as loan relationships) may apply if a reporting fund held more that 60% by value of its investments in debt type assets at any time during an investing company’s accounting period - see the Corporate Finance Manual (‘CFM’)).