IFM12554 | Offshore Funds: Reporting Funds: computation of reportable income: transactions not treated as trading: introduction

Regulation 73 of SI 2009/3001

Chapter 6 of Part 3 of the Regulations provide certainty that specified transactions will not be treated as trading transactions for reporting funds that meet the ‘equivalence condition’ at regulation 74, and the genuine diversity of ownership (‘GDO’) condition at regulation 75 in that chapter. The list of applicable transactions (the ‘investment transactions list’) is contained in the Investment Transactions (Tax) Regulations 2014 – regulation 80, see IFM12557.

The following pages provide further guidance on the conditions and scope of investment transactions.

Tax-transparent Funds

The ‘investment transactions list’ does not apply to tax-transparent funds as the income of such funds arises directly to their investors (regulation 49(3)).