New offshore funds manual
HMRC have published a new manual entitled the ‘Offshore Funds Manual’ which covers the definition of an offshore fund and the operational rules of the offshore funds regime.
The publication of this manual follows the introduction of the 2009 Regulations which were drafted 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.
HMRC had published draft guidance back in October 2009 and this manual incorporates comments received as well as other items of relevant guidance which had been in draft form. The full text of the manual can be accessed using the following link:www.hmrc.gov.uk/offshorefunds/new-manual.htm
Whilst this is a final version, HMRC will continue to accept comments from taxpayers who find inconsistencies or errors within the document which will be incorporated into future updates and electronic editions of the manual.
Comments should be sent to:
HM Revenue and Customs
100 Parliament Street