Tax is charged on the ‘offshore income gain’ arising on the disposal of an interest in an offshore fund (ICTA 1988, s. 761(1)). The offshore income gain is calculated in accordance with the provisions of ICTA 1988, Sch. 28, Pt. I, para. 1, 5.
Meaning of ‘offshore income gain’
The meaning of offshore income gain depends upon whether the investor acquired his interest in the fund before or after 1 January 1984. The intention is to exclude from the income tax charge the gain accrued prior to that date.