IFM12554 - Offshore Funds: Reporting Funds: computation of reportable income: transactions not treated as trading: introduction
Regulation 73 of SI 2009/3001
Chapter 6 of Part 3 of the Regulations provide certainty that specified transactions will not be treated as trading transactions for reporting funds that meet the ‘equivalence conditionâ€� at regulation 74, and the genuine diversity of ownership (‘GDOâ€�) condition at regulation 75 in that chapter. »Ê¹ÚÌåÓýapp list of applicable transactions (the ‘investment transactions listâ€�) is contained in the Investment Transactions (Tax) Regulations 2014 â€� regulation 80, see IFM12557.
»Ê¹ÚÌåÓýapp following pages provide further guidance on the conditions and scope of investment transactions.
Tax-transparent Funds
»Ê¹ÚÌåÓýapp ‘investment transactions listâ€� does not apply to tax-transparent funds as the income of such funds arises directly to their investors (regulation 49(3)).