An interest in a reporting offshore fund is an asset for capital gains purposes and on the disposal of that asset a chargeable gain or an allowable loss will arise (SI 2009/3001, reg. 99). For disposals on or after 1 January 2018, reg. 99 no longer applies to interests in transparent offshore funds which, although still treated as chargeable gains assets, are now dealt with under TCGA 1992, s. 103D alongside co-ownership authorised contractual schemes (¶785-020).
Want to read more?
This content requires a Croner-i Tax and Accounting subscription.