This content considers the tax treatment of distributions made by non-transparent reporting funds. For transparent reporting funds funds, see ¶783-900.

Participants within the charge to income tax

The income tax treatment of a distribution depends on the status of the offshore fund (i.e. corporate or otherwise) and the nature of its investments (i.e. whether or not it meets the qualifying investments test at ITTOIA 2005, s. 378A; see below); as follows (the Offshore Funds (Tax) Regulations 2009 (SI 2009/3001), reg. 95 and 96):

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