Where an offshore income gain arises on the disposal of an interest in a non-reporting fund, or in some cases on the disposal of an interest in a reporting fund (see below), the gain is treated as income subject to tax as follows (the Offshore Funds (Tax) Regulations 2009 (SI 2009/3001), reg. 18):

where the person is within the charge to income tax, the charge to tax under ITTOIA 2005, Pt. 5, Ch. 8 (miscellaneous income: income not otherwise charged; see ¶129-280), subject to some modifications, applies for the year of assessment in which the disposal is made; and

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