Jurisdiction(s):
United Kingdom

Key definition

Offshore fund definition

What does Offshore fund mean? In practice, an offshore fund is an investment vehicle established outside the UK that pools investors’ money, gives investors no day‑to‑day control over management, and allows them to realise their interests by reference to net asset value (NAV). For UK tax purposes the term is defined in legislation: it broadly means a “mutual fund” within section 355(1) of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010), to which the Offshore Funds (Tax) Regulations 2009 apply. Key legal features and significance: - Collective investment arrangements with limited investor control. - A reasonable expectation of redemption or realisation based wholly...

Non-reporting offshore funds under the Offshore Funds (Tax) Regulations 2009: UK tax on OIGs, computations, status-change elections, exceptions, CGT interaction and distribution treatment

Published by a LexisNexis Tax expert

Practice notes

STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime

Finance Act 2025 (FA 2025), which received Royal Assent on 20 March 2025, delivers the repeal of the remittance basis and introduces a residence-based system with effect from 6 April 2025. FA 2025 also replaces domicile as the principal criterion for determining exposure to inheritance tax.

Updates to the rules for determining excluded property status
Abolition of the protected settlements status for offshore trusts
Changes to overseas workday relief

For details on these measures, see: Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26.

A non-reporting Offshore fund is any offshore fund that does not have reporting Fund status for a particular period of account. For what constitutes an offshore fund, see Practice Note: Tax and offshore funds—what is an offshore fund?. For information on reporting Funds, see Practice Notes: Tax and offshore funds—the reporting fund regime and Tax and offshore funds—requirements of the reporting fund regime...

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Michael Alliston

Norton Rose Fulbright

Michael Alliston is a tax lawyer based in London. He advises on a wide range of corporate tax matters, including M&A, corporate reorganizations, capital markets transactions and financings.Michael's practice comprises a mix of transactional and stand-alone advisory work. He assists companies across a wide variety of sectors, including energy, infrastructure, financial institutions, funds, real estate and transport.Michael has particular experience advising M&A and tax risk underwriters....

Web page updated on 21/05/2026

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