UK resident trustees

The general principle is that where participants dispose of a material interest in a non-reporting offshore fund, the gain that arises is subject to income tax (these and other relevant terms are defined in TIOPA 2010, Pt. 8; see ¶783-000ff.). Where trustees dispose of such an interest, an income tax charge is imposed by Offshore Funds (Tax) Regulations 2009 (SI 2009/3001), reg. 17, which is automatically subject to the special trust rate by virtue of ITA 2007, s. 482 – see ¶352-800.

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