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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: long-term insurance funds

IFM13466 | Offshore Funds: investors in non-reporting funds: exceptions to the charge to tax: long-term insurance funds

From HM Revenue & Customs · Investment Funds Manual

Regulation 27 of SI 2009/3001

Where an interest in an offshore fund that is an asset of an insurance company’s long-term insurance fund is disposed of, any gain arising on disposal will not be taxed as an offshore income gain.

In this context, ‘insurance company’ and ‘long-term insurance fund’ have the same meaning as in section 431(2) of ICTA. A long-term insurance fund is, broadly, the funds that an insurance company maintains to meet its long term liabilities, such as payments to annuitants.

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