New offshore fund regulations
The new Offshore regulations (SI 2009 – No. 3001) will come into force on 1 December 2009. The regulations are designed to make proper provision for the taxation of UK resident investors in offshore funds in respect of income tax, corporation tax and capital gains tax.
The regulations have been drafted with the following policy objectives:
- To remove UK barriers to multi-tiered fund structures
- To simplify the offshore funds tax regime
- To seek to achieve economic parity with UK investors in UK authorised funds
- To build on existing anti-avoidance rules to ensure that UK resident investors do not obtain unintended tax advantages
- To develop a modernised regime.