Jurisdiction(s):
United Kingdom

Related legal acts

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...

UK offshore funds: reporting fund regime—eligibility, application, investor tax effects, constant NAV rules, and genuine diversity of ownership clearance

Published by a LexisNexis Tax expert

Practice notes

‘reporting fund’

A ‘reporting fund’ is an offshore fund that has obtained reporting fund approval and has not departed the regime, whether voluntarily or by exclusion. In essence, UK investors in such funds are taxed each year on their portion of the fund’s reported income, irrespective of whether that income is paid out or retained. This allows capital gains treatment to apply when they dispose of their interest. For offshore funds that do not report income in this manner (‘non-reporting funds’), disposals by investors are taxed as income. The governing provisions are in Part 3 of the Offshore Funds (Tax) Regulations 2009, SI 2009/3001 (the Offshore Funds Regulations). For the UK tax definition of an ‘offshore fund’, see Practice Note: Tax and offshore funds—what is an offshore fund?

This Practice Note covers:

the eligibility criteria and application process for the reporting fund regime
the consequences of entering the reporting fund regime
a brief overview of the continuing obligations and requirements for funds within the reporting regime—for more on a reporting fund’s ongoing duties and obligations, including...

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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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