IFM08530 - Taxation of income arising to UK investors in ACS: investors within the charge to Corporation Tax

Companies and other investors within the charge to corporation tax (CT) should include their share of income from a CoACS as part of the calculation of their CT liability. That includes any income allocated to investors from investments in offshore funds (see IFM8350 to IFM8360).

Companies should make the usual adjustments for debits and credits arising from loan relationships and derivative contracts held within the CoACS. Those amounts form part of the adjustment to base cost for the purposes of the chargeable gains calculation – see section 103D(4) to (7) of the Taxation of Chargeable Gains Act 1992.

The Corporate Finance Manual gives more details of the treatment of loan relationships, derivatives, foreign exchange differences and other financial instruments.