Commentary

B5.709 Interaction with capital gains tax

Business tax
Business tax | Commentary

B5.709 Interaction with capital gains tax

Business tax | Commentary

B5.709 Interaction with capital gains tax

The disposal of an interest in an offshore fund may give rise to an offshore income gain and also be a disposal for capital gains tax purposes. In such a case, the consideration for the disposal for capital gains tax purposes is reduced by the amount of the offshore income gain1. Where there is a loss such that the offshore income gain is nil (see B5.708), the loss may be treated as a loss for capital gains tax purposes2.

If the disposal is a part disposal for capital gains tax purposes3, so that an apportionment

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