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HMRC internal manual

Savings and Investment Manual

HM Revenue & Customs
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Collective investment schemes: offshore funds: what is an offshore fund?

What is an offshore fund?

The information in this manual applies to transactions up to 30 November 2009. The Offshore Funds Manual is currently being updated for the offshore funds regime from 1 December 2009.

Only collective investment schemes are offshore funds - see the Offshore Funds Guide (OSFG 01040) on the HMRC website ().

An offshore fund is a collective investment scheme that takes the form of a non-resident unit trust or any other arrangements (which can include companies) that take effect under foreign law and create rights in the nature of co-ownership.

Most offshore funds are managed by well-known UK institutions and the name of such institutions often appears in the name of the fund.

The nature of a taxpayer’s investment may not always be clear at first sight. There are pointers to the existence of an offshore fund - for example, shares, units or sale proceeds denominated in a currency other than sterling, or investments in concerns bearing the end-title SA, NV, BV etc. The inclusion of the words ‘Fund Ltd’ in the title will usually suggest an offshore fund.

The Collective Investment Schemes Centre Sheffield keep a list of funds granted distributing fund status.

See . This will help you identify distributing funds.

An additional source of information is provided by the Financial Times which lists many offshore funds and also UK authorised unit trusts. The Collective Investment Schemes Centre Sheffield is ready to help both generally and in specific cases of doubt or contention.