»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýapp purpose of the offshore fund regime is to ensure that income cannot be rolled up free of tax with any subsequent gain on disposal being taxed only as a capital gain. Both the 1984 and 2009 rules achieve this by charging any gains on disposals of interests to tax as income (‘offshore income gainsâ€�, or ‘OIGsâ€�) in arrangements that do not distribute, or report income.

However, where it is not possible to roll-up income in such a way that it would not be taxed as income, there is no need to apply the offshore funds rules. This may be the case where a tax charge is imposed by other parts of the Tax Acts on income arising from an investment in arrangements that may come within the definition of an offshore fund. »Ê¹ÚÌåÓýappre are other circumstances where it would not be desirable to charge a disposal of an interest in an offshore fund to tax as an OIG. »Ê¹ÚÌåÓýapp Offshore Funds (Tax) Regulations 2009 therefore set out specifically when a charge to tax on an OIG will not arise.

»Ê¹ÚÌåÓýapp following pages provide guidance on the exceptions in the regulations.