The Government has announced legislation to restore the non-payable dividend tax credit for offshore funds which are largely invested in equities.
Changes will come into effect after 22 April and will impact on individuals receiving distributions from offshore funds. The rules will also state that where the offshore fund is "substantially" invested in interest bearing assets, individuals receiving distributions will be treated for tax purposes as having received interest and not a dividend. Since 6 April 2008, individual shareholders with shareholdings of less than 10% in non-UK resident companies have been entitled to a non-dividend tax credit. However, the tax credit was withdrawn for offshore funds as some collective investme...
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