Certain contractual arrangements have historically been treated as transparent for both income and capital gains purposes (for example, Luxembourg Fonds Commun de placement (‘FCPs’)). But whilst such funds came within the previous definition of an offshore fund, the offshore funds regime for taxing offshore income gains was not applicable as investors were treated as holding, for capital gains purposes, interests in the underlying assets rather than in the fund itself.

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.