IFM13235 - Offshore Funds: participants in offshore funds: participants within the charge to corporation tax: reporting funds that are constant NAV funds
Regulation 118 of SI 2009/3001
A “constant NAV fund” is an offshore fund whose net asset value (expressed in the currency in which units are issued) does not fluctuate by more than an insignificant amount throughout the fund’s existence, as a result of the nature of the fund’s assets, and the frequency with which the fund distributes its income. The distributions are treated as income of the investors at the time they are made.