Commentary

B5.703 Application of TCGA 1992 to offshore funds

Business tax
Business tax | Commentary

B5.703 Application of TCGA 1992 to offshore funds

Business tax | Commentary

B5.703 Application of TCGA 1992 to offshore funds

Disposals on or after 1 January 2018

For disposals on or after 1 January 2018 the rules applying to the calculation of chargeable gains on offshore transparent funds1 are brought in line with those applying to authorised contractual schemes which are co-ownership schemes2 (see D8.146). So for disposals from that date a unit in such a fund is treated as an asset, and therefore a participant's interest in the fund property is disregarded for these purposes. The chargeable gains computation on disposal should take account of expenditure incurred under the old rules up to 31 December 2017 and under the new rules from 1 January 20183. In calculating the gain, income from the fund which is taken into account as a receipt or other

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