Commentary

B5.701 Introduction

Business tax
Business tax | Commentary

B5.701 Introduction

Business tax | Commentary

Division B5.7     Offshore Funds

For updates affecting this Division please see Part B0 Updates

Offshore funds—background

B5.701 Introduction

Following consultation in early 2008, legislation was introduced in FA 2008, ss 41, 42 enabling the tax regime relating to persons with an interest in an offshore fund to be replaced by regulations. FA 2008, ss 41, 42 have subsequently been rewritten in Taxation (International and Other Provisions) Act 2010, ss 354–363A (Pt 8). The Regulations1, which came into force on 1 December 2009, were introduced to modernise the rules for the taxation of investors in offshore funds so that, as far as possible, UK investors make their investment decisions for commercial reasons and not to obtain unintended tax advantages2. The original UK tax regime for offshore funds was introduced in 1984, broadly to establish the tax treatment of activities that seek to use certain offshore funds to convert income flows into capital gains. However, the market place for funds has changed significantly

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