Offshore funds
Abbreviations
Accounts, preparation of
Annual payments to non-residents
Authorised investment funds investing in non-reporting offshore funds
Breaches of requirements
Constant NAV funds
Differences between reported income and reportable income
Generally
Information not provided
Leaving the regime
Report that is incorrect or incomplete
Serious breaches
Capital gains tax
Certification
Application
Wholly-owned subsidiaries dealing in commodities
Change of accounting policy
Charitable trusts, exemption for income gains
Civil proceedings for recovery of property
Classification
Collective investment schemes
Co-ownership schemes
Exchanges, mergers and reconstructions
Transfer of assets
Commencement of new regime
Commodities
Subsidiaries dealing in
Computation of reportable income
Adjustments to be made
Capital items
Effective interest income or comparable amounts
Equalisation arrangements
Generally
Non-reporting funds
Other reporting funds
Starting point
Transparent reporting funds
Wholly-owned subsidiaries
Conditions for distributor status
Consequential amendments
Constant net asset value funds
Controlled foreign companies
Corporation tax
Defined expressions
Derivative contracts
Disposals
Charge to tax
Computation of offshore income gains
Conversion of non-reporting funds
Exceptions to charge
Interaction with capital gains
Meaning
Non-resident companies
Distributing funds
Equalisation arrangements
Requirements as to distributions
Transitional provisions
Umbrella funds
Distributor status
Equalisation arrangements
Equalisation element, disposals involving
Full distribution policy
General duties
Generally
Preparation of accounts
Gifts to charity
Guaranteed return fund, meaning
Holdings treated as creditor relationship rights
Disregard of investments and liabilities where tax avoidance motive
Generally
Opening valuations
Inheritance tax
Interest in an offshore fund, meaning
Investment transactions
Carbon emission trading products
Collective investment schemes
Contracts for differences
Futures
Generally
Information, HMRC's powers
Loan relationships
Meaning
Options
Relevant contract, meaning
Reporting period
Reports to participants
Summary computation of reportable income
Investment trust having interest in non-reporting funds
Investment trusts with interests in non-reporting funds
Investors participating in, tax treatment
Acquisition cost
Capital gains tax
Commencement
Elections modifying commencement
Leaving the regime
Loan relationships
Market value, meaning
Material interests
Material interests in non-qualifying offshore funds
Equalisation arrangements
Meaning
More than one class of interest
Mutual fund, meaning
New classes of interest within existing main funds
New funds within existing umbrella funds
Non-residents, annual payments to
Non-trading transactions
Clearance procedure
Equivalence condition
Generally
Genuine diversity of ownership condition
Offshore income gain
Children of settlor
Investment trusts
Settlor's income
Old regime
Overview
Participant, meaning
Participants in non-reporting funds
Authorised investment funds investing in non-reporting offshore funds
Chargeable gains
Chargeable gains, deduction of offshore income gains
Charges to tax
Charitable companies and charitable trusts, exception from charge
Conversion of non-reporting fund into reporting fund
Death, disposal of interests
Disposal of assets, charge to tax on
Disposal of interests in non-reporting funds
Distributions, charge to tax on amounts treated as
Exceptions from charge to tax
Exchange of interests of different classes
Exchange of units for those in another collective investment scheme
Generally
Income and distributions, transparent/non-transparent funds
Interests in transparent funds, exceptions from charge
Loans other than participating loans, exception from charge
Long-term insurance funds of insurance companies, exception from charge
Material disposal, meaning
Non-resident settlements, gains of
Offshore income gains
Reconstructions involving issue of units/issue of securities
Remittance basis
Rights in certain existing holdings, exception from charge
Trading stock, exception from charge
Transfer of assets abroad
Unlisted trading company exception
Participants in reporting funds
Anti-avoidance provisions, financial traders
Charge to tax
Charitable companies and charitable trusts
Corporation tax charge
Deemed disposals of interests
Disposals of interests
Disposals of interests and deemed disposals of interests
Distributions made by fund
Excess of reported income over distributions made
Financial traders with holdings in diversely owned funds
Financial traders, anti-avoidance provisions
Generally
Income tax charge
Reported income, tax treatment
Reports to
Participants in, tax treatment
Arrangements comprising more than one class of interest
Exceptions to meaning of mutual fund
Mutual fund, meaning
Offshore fund, meaning
Participant, meaning
Participation, meaning
Regulations, power to make
Relevant income-producing asset
Umbrella arrangements
Period of account, meaning
Proposed prospectus, meaning
Prospectus, meaning
Qualifying investments test
Generally
Hedging relationship
Meaning of qualifying investments
Power to change qualifying investments
Qualifying holdings
Repeals
Reporting funds
Accounts, preparation of
Annual reporting requirements
Appeals against refusal to amend a statement
Appeals against rejection of application/exclusion from regime
Application to enter regime
Breaches of requirements
Capital items, adjustments for
Carbon emission trading products, transactions in
Clearance procedures, equivalence and genuine diversity of ownership condition
Computation of reportable income
Constant NAV funds
Contracts for differences, transactions in
Conversion of non-reporting fund into
Duties of
Entry into regime
Equalisation arrangemenst, not operating
Equalisation arrangements
Equivalence condition
Existing fund application
Foreign currency, transactions in
Form of application
Future fund application
Futures, transactions in
General duties
Generally
Genuine diversity of ownership condition
HMRC's response
Index tracking funds
Information to be provided
Interest in other reporting funds, income from
Interest income or other comparable amounts, adjustments for
Investment transactions carried out by diversely owned funds
Leaving the regime
Loan relationships, transactions in
Meaning
Non-reporting funds, income from
Not operating equalisation arrangemenst
Options, transactions in
Participants, tax treatment
Participants, treatment of
Reports to participants
Stocks and shares, transactions in
Time limits for making/withdrawing applications
Transactions not treated as trading
Transparent
Transparent reporting funds
Units in collective investment schemes, transactions in
Wholly-owned subsidiaries, income from
Reports to participants
Contents of
Making a report
Reporting period
Residence, undertakings for collective investment in transferable securities
Tax year, meaning
Transitional provisions and savings
Transparent funds
Adjustment in relation to income from other reporting funds/non-reporting funds
Generally
Meaning
Reportable income
Tribunal, meaning
Trustees
UK equivalent profits
Creditor relationships
Derivative contracts
Generally
Umbrella arrangements
Undertakings for collective investment in transferable securities
Residence
UCITS fund, meaning
Unlisted trading company exception
