Where an offshore income gain arises, it is calculated in the same way as a gain on the disposal of a chargeable asset; i.e. by reference to the capital gains rules at the Taxation of Chargeable Gains Act 1992. However, the capital gains rules are modified in some instances, as follows (the Offshore Funds (Tax) Regulations 2009 (SI 2009/3001), reg. 38–43):

(1)where a loss is calculated, the offshore income gain is nil;

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