One of the major differences between the charge on offshore gains and the capital gains tax charge is that in the former case a charge is made on the death of an individual entitled to a material interest. Whereas under the capital gains tax legislation, assets are deemed to be acquired, but not disposed of, on an individual’s death, a material interest in a non-qualifying offshore fund of which the deceased was ‘competent to dispose’ is deemed to be disposed of by the deceased for a consideration equal to its market value at the date of death (ICTA 1988, s. 757(3)). This does not, however, apply to funds operating equalisation arrangements (see ¶784-690).

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