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Official guidance
Investment Funds Manual

IFM13450 · Offshore Funds: investors in non-reporting funds: exceptions to the charge to tax

  • IFM13452 · General
  • IFM13454 · Interests treated as loan relationships
  • IFM13456 · Interests treated as derivative contracts
  • IFM13458 · Intangible fixed assets
  • IFM13460 · Excluded indexed securities
  • IFM13462 · Rights arising under a policy of insurance
  • IFM13464 · Trading stock
  • IFM13466 · Long-term insurance funds
  • IFM13468 · Non-participating loans
  • IFM13470 · Interests in certain transparent funds
  • IFM13472 · Rights in certain existing holdings
  • IFM13474 · Charitable companies & charitable trusts
  • IFM13476 · Registered pension schemes
  • IFM13478 · Unlisted trading company exception
  1. Offshore Funds: investors in non-reporting funds: exceptions to the charge to tax: contents
  2. Offshore Funds: investors in non-reporting funds: exceptions to the charge to tax: excluded indexed securities

IFM13460 | Offshore Funds: investors in non-reporting funds: exceptions to the charge to tax: excluded indexed securities

From HM Revenue & Customs · Investment Funds Manual

Regulation 25(5) of SI 2009/3001

ITTOIA05/S433 explains the meaning of ‘excluded indexed securities’. They are outside the deeply discounted security rules, and are instead taxed under the capital gains rules. There is further guidance on excluded indexed securities in the Savings and Investment Manual.

Where an interest in an offshore fund would fall to be treated as an excluded indexed security, any gain arising on disposal will not be taxed as an offshore income gain, and the capital gains treatment is preserved.

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