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20 May 2008
HMRC have published for consultation partial draft regulations on the taxation of investors in offshore funds
HMRC have published for consultation partial draft regulations on the taxation of investors in offshore funds - and to show the intended use of the powers in clauses 38 and 39 of the Finance Bill 2008.
These partial draft regulations do not change the definition of an offshore fund. The Government will continue discussing a new characteristics based definition with industry and will introduce this in Finance Bill 2009.
The partial draft regulations do not cover the following points which will be included in the next draft:
- The issue of transitional arrangements for funds which currently have distributing status under the existing offshore funds regime. The Government welcomes views on what transitional arrangements should be made.
- Arrangements for taking equalisation into account in calculating the reported income which will be based on current rules.
The Government has invited comment on the points above and the partial draft...
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