Offshore funds (pre-1 December 2009)
Bare trustees and nominees
Certification procedure
Appeals against refusal or withdrawal
Application
Assessment
Information
Postponement of tax pending
Refusal or withdrawal
Chargeable gains
Computation of tax
Beneficiaries of non-resident trusts
Equalisation arrangements
Generally
Interests acquired before 1 January 1984
Losses
Non-resident companies
Offshore income gain, calculation
Persons chargeable
Persons resident or domiciled outside the UK
Schedule D, Case VI, assessment under
Trustees and beneficiaries
UK-resident trusts
Unindexed gain, calculation
Distributing funds, exemption
Account period, meaning
Distribution test
Funds with interests in other funds
Investment in
Qualifying/non-qualifying funds
Distribution test
Attribution of income and distributions to account periods
Commodity income
Conditions to be satisfied
Equalisation arrangements
Head of charge applicable
UK equivalent profits
Equalisation arrangements
Classes of interest
Commodity income
Computation of tax
Distribution test
Generally
Meaning
Umbrella funds
Funds with interests in other funds
De minimis holdings in companies, pre-July 2004
Distributing funds
Generally
Limit on interests in other funds and other investment restrictions
Trading companies, pre-July 2004
Wholly-owned subsidiaries, pre- and post-July 2004
General summary
Computation of tax
Exemptions, distributing funds
Generally
Occasion of charge
Procedure
Gifts to charities, deductions
Interaction with capital gains tax
Loan relationships
Material interests
Bank loans
Insurance rights
Majority interest, exception
Meaning
Non-qualifying, identification of securities
Offshore fund, meaning
Trading ventures, exception
Meaning
Occasion of charge, disposals
Company reconstructions
Deemed disposal on death
Exchange of interests of different classes post-July 2004
Generally