IFM13274 - Offshore Funds: participants in offshore funds: participants within the charge to corporation tax: disposals: disposals of tax transparent reporting funds
Even where regulation 29 of SI 2009/3001 is capable of applying to exempt gains on disposal of interests in an income transparent fund, the fund can still choose to apply for reporting fund status. A fund may do so because, for example, it wishes to exceed the percentage limit for investment in other non-reporting funds, it does not wish to monitor that limit or it considers that being approved as a reporting fund will be beneficial in attracting UK investors.
»Ê¹ÚÌåÓýappse funds are transparent for income purposes only and remain opaque for capital gains purposes. So, the capital gains charge will only arise to a UK investor on the disposal (deemed or actual) or part-disposal by the investor of their investment in the fund and not on the disposal by the fund of any of its underlying assets.