The UK's offshore fund tax rules are changing. Subject to the outcome of a final consultation, with effect from 1 October 2009, offshore funds will be able to elect for ‘reporting fund' status.
This article explains the proposed changes to the existing ‘distributing fund' regime and identifies the key issues which offshore funds and their managers should be considering at this time. This will be of major importance in enabling UK resident investors in offshore funds to obtain favourable capital tax gains treatment for their investment in such offshore funds. It should provide for a less burdensome certification process and greater certainty for funds and their investors. Current Distributing Funds regime Under the existing regime, unless an offshore fund is certified by HM ...
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