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Legislation
The Offshore Funds (Tax) Regulations 2009

Crossheading Tax treatment of the reported income of the fund in the hands of participants

  • Section 94 Reported income: general provisions
  • Section 94A Equalisation amounts not treated as distributions
  • Section 95 Participants chargeable to income tax: corporate funds
  • Section 96 Participants chargeable to income tax: other non-transparent funds
  • Section 97 Participants chargeable to income tax: transparent funds
  • Section 98 Participants chargeable to corporation tax
  1. Tax treatment of the reported income of the fund in the hands of participants
  2. Participants chargeable to income tax: transparent funds

Regulation 97 | Participants chargeable to income tax: transparent funds

From legislation.gov.uk

(1)This regulation applies if—

(a)a reporting fund is a transparent fund, and

(b)some or all of the excess specified in regulation 94(2) is treated as income of a participant by virtue of that provision.

(2)Any amount to which paragraph (1) applies is charged to income tax under Chapter 8 of Part 5 of ITTOIA 2005 as relevant foreign income within the meaning given by section 830 of ITTOIA 2005 for the year of assessment in which the distribution is made, but sections 688(1) and 689 of ITTOIA 2005 do not apply.

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