»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýappre are a number of tax rules which ensure that income accruing within transparent offshore funds is taxable as it arises as the income of any investors within charge to UK tax.

»Ê¹ÚÌåÓýapp rules which apply to Co-ownership Authorised Contractual Schemes (CoACS) are contained in Part 3 of »Ê¹ÚÌåÓýapp Co-ownership Authorised Contractual Schemes (Tax) Regulations 2017 (SI 2017/1209).

»Ê¹ÚÌåÓýapp rules differ depending on whether the offshore fund in which the CoACS has invested is a reporting fund or a non-reporting fund. A reporting offshore fund is one where the fund has entered a special regime administered by HMRC in which the fund must submit to investors on an annual basis details of their share of the fund’s income, whether distributed or not, and a report of how that income was calculated to HMRC. Investors in a reporting fund are taxable on any income distributions received and on their share of any excess income for a period of account. A non-reporting fund is any offshore fund that is not a reporting fund. See IFM08360 for more details.

»Ê¹ÚÌåÓýapp rules for offshore funds are contained in »Ê¹ÚÌåÓýapp Offshore Funds (Tax) Regulations 2009 (SI 2009/3001) â€� see IFM12000.