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Official guidance
Investment Funds Manual

IFM13400 · Offshore Funds: participants in offshore funds: the charge to tax on disposal of an interest in a non-reporting fund

  • IFM13410 · Overview
  • IFM13412 · The charge to tax
  • IFM13414 · The charge to tax: income tax
  • IFM13416 · The charge to tax: corporation tax
  • IFM13420 · Non-resident settlements
  • IFM13425 · Effect of section 87 attribution rules on offshore income gains arising in non-resident settlement structures up to 5 April 2025
  • IFM13430 · Effect of residence / domicile of beneficiary on offshore income gains arising in non-resident settlement structures that are attributed under section 87 TCGA rules - regulation 20 up to 5 April 2025
  • IFM13432 · Allocating capital payments between offshore income gains and chargeable gains that arose in non-resident settlements until 5 April 2025- regulation 20(4)
  • IFM13434 · Example showing how a UK resident but non-UK domiciled beneficiary may not be chargeable to tax on an offshore income gain arising in a non-resident settlement prior to 6 April 2008 - paragraph 100 Schedule 7 FA 2008
  • IFM13436 · Example showing how a UK resident but non-UK domiciled beneficiary may benefit from a ‘rebasing’ election - paragraph 101 Schedule 7 FA 2008
  • IFM13438 · Example showing how a UK resident but non-UK domiciled beneficiary may not benefit from a ‘rebasing’ election - paragraph 101 Schedule 7 FA 2008
  • IFM13440 · Transfer of assets abroad
  • IFM13442 · Offshore income gains arising to certain non-resident companies
  • IFM13444 · Application of other TCGA provisions
  1. Offshore Funds: participants in offshore funds: the charge to tax on disposal of an interest in a non-reporting fund: contents
  2. Offshore Funds: participants in offshore funds: the charge to tax on disposal of an interest in a non-reporting fund: the charge to tax: corporation tax

IFM13416 | Offshore Funds: participants in offshore funds: the charge to tax on disposal of an interest in a non-reporting fund: the charge to tax: corporation tax

From HM Revenue & Customs · Investment Funds Manual

Regulation 18 of SI 2009/3001: Participants within the charge to corporation tax

Offshore income gains are charged to tax as miscellaneous income under Chapter 8 of Part 10 of CTA 2009, for the accounting period in which the disposal is made (regulation 18(4)).

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