[HMRC Tax Bulletin 79, October 2005]

Accounting periods starting on or after 1 January 2006

All statutory references are to the Income and Corporation Taxes Act 1988 unless otherwise stated.

We have been considering whether an offshore income gain computed under section 761 falls within the definition of eligible investment income for the purposes of section 842.

Investment trust companies may have disposed of material interests in offshore funds that do not qualify for “distributing fund” status.

Our previous view was that an offshore income gain arising from such a disposal would qualify as eligible investment income for the purposes of section 842.

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