The following Tax guidance note Produced in partnership with Michael Alliston of Herbert Smith Freehills LLP provides comprehensive and up to date legal information covering:
This Practice Note describes how to apply for reporting offshore fund status, the effect of entering the reporting fund regime and the process for obtaining clearance from HM Revenue and Customs (HMRC) in respect of whether the fund in question satisfies certain requirements. A 'reporting fund' is a offshore fund within the meaning of section 355(1) of the Taxation (International and Other Provisions) Act 2010 that has applied for and been approved as a reporting fund, and that has not voluntarily left the reporting fund regime or been excluded by HMRC under the Offshore Funds (Tax) Regulations 2009 (the Regulations).
This Practice Note describes:
the eligibility requirements for, and the process of applying for, reporting fund status
the effect of entry into the reporting fund regime
the process for obtaining clearance in respect of certain requirements to be a reporting fund, and
the modification of the rules for constant net asset value (NAV) funds
When considering when and how to submit an application for reporting fund status, it is important to address some key issues, including:
who can apply
whether the fund is converting from a non-reporting fund
the precise requirements for the contents of the application
the form, timing and rules on the
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