Offshore Funds Manual: Main Contents
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This manual explains how UK resident investors in offshore funds are treated for tax purposes. It sets out the background to the offshore funds tax regime that applied to UK investors in offshore funds from 1984 onwards, and provides detailed guidance explaining how UK investors are treated under the replacement regime now at Part 8 of the Taxation (International and Other Provisions) Act 2010 and the Offshore Funds (Tax) Regulations 2009 (SI 2009/3001) as subsequently amended by SI 2009/3139 and SI 2011/1211.
Please note that, unless otherwise stated, all references in the OFM to Regulations or a particular regulation are a reference to the Offshore Funds (Tax) Regulations 2009 (including amendments made up to May 2011) unless otherwise stated.
If you have any comments or questions on the contents of this manual please direct them to the HMRC Collective Investment Schemes Centre (CISC) who will maintain a list of any issues to be addressed. See also the list of Frequently Asked Questions on the CISC website.
Introduction
| OFM00500 |
Background to the treatment of UK investors in offshore funds |
| OFM01000 |
Overview of the 1984 regime for offshore funds |
| OFM02000 |
Overview of the 2009 regime for offshore funds |
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Definition of an offshore fund
Top
The 2009 offshore funds regime
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Investors in non-reporting funds
| OFM12000 |
Introduction |
| OFM13000 |
Distributions: the charge to tax |
| OFM14000 |
Disposals of interests |
| OFM15000 |
The charge to tax on disposals of interests |
| OFM16000 |
Exceptions to the charge to tax |
| OFM17000 |
Computation of offshore gains |
| OFM18000 |
Deduction of offshore income gains in computing capital gains |
| OFM19000 |
Conversion of a non-reporting fund to a reporting fund: consequences for participants in non-reporting fund - Regulation 48 |
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Reporting funds
| OFM20000 |
Introduction |
| OFM21000 |
Application for reporting fund status |
| OFM22000 |
Duties of reporting funds |
| OFM23000 |
Preparation of accounts |
| OFM24000 |
Computation of reportable income |
| OFM25000 |
Computation of reportable income: transactions not treated as trading |
| OFM26000 |
Reports to participants |
| OFM27000 |
Tax treatment of participants in offshore funds |
| OFM28000 |
Provision of information to HMRC |
| OFM29000 |
Breaches of reporting fund conditions |
| OFM30000 |
Constant NAV funds |
| OFM31000 |
Leaving the reporting fund regime |
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Transitional rules
