Powered by Lexis+®
Jurisdiction(s):
United Kingdom
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...
Read More
UK offshore funds tax: characteristics-based definition of an offshore fund—mutual fund conditions A–F, exceptions for closed-ended funds, entity types and umbrella arrangements
Published by a
LexisNexis Tax expert
Practice notes
Background to the UK’s Offshore funds Rules
Targeted tax legislation for offshore funds first appeared in 1984. Up to that point, UK Investors in non‑UK investment vehicles could accumulate income offshore and, when their holdings were realised (for example on a sale of their interest), the proceeds were charged at capital gains rates rather than income tax rates. The 1984 'offshore funds' regime addressed this position by treating as income any gains arising on disposals of material interests in 'offshore funds'. For tax purposes, the notion of an 'offshore fund' was anchored to a regulatory definition for the sector. Certain provisions offered an exception from that treatment where a particular offshore fund distributed at least 85% of its income and UK‑equivalent profits to investors each period. Where a fund made such distributions, an investor's disposal of their interest continued to receive capital gains tax treatment on exit. The intention behind the 1984 rules was to secure consistent tax outcomes for interests held by UK investors in offshore funds on the one hand and in UK Funds on the other. The UK tax framework for offshore funds was then significantly revised across the regime in 2009...
To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.
Web page updated on 22/05/2026
Popular documents
When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...
This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...
Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...
I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...
Discover more from LexisNexis
