Revenue Note for Guidance

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Revenue Note for Guidance


Offshore funds:supplementary provisions

747A Capital gains tax: rate of charge

This section provides for a capital gains tax rate of 40 per cent on the disposal of units in certain offshore funds by a unit holder. The type of fund referred to is known as a distributing fund and is one which distributes at least 85 per cent of its income on an annual basis. In this case, capital gains on the disposal of units in the fund are subject to capital gains tax, and annual income from the units is subject to income tax.

In the case of non-distributing offshore funds, which accumulate income and gains rather than distributing them, gains on the disposal of units are subject to income tax under the provisions of Chapter 2 of Part 27.

Relevant Date: Finance Act 2021