IFM13400 - Offshore Funds: participants in offshore funds: the charge to tax on disposal of an interest in a non-reporting fund: contents
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IFM13410Overview
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IFM13412The charge to tax
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IFM13414The charge to tax: income tax
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IFM13416The charge to tax: corporation tax
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IFM13420Non-resident settlements
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IFM13425Effect of section 87 attribution rules on offshore income gains arising in non-resident settlement structures
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IFM13430Effect of residence / domicile of beneficiary on offshore income gains arising in non-resident settlement structures that are attributed under section 87 TCGA rules
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IFM13432Allocating capital payments between offshore income gains and chargeable gains arising in non-resident settlements
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IFM13434Example showing how a UK resident but non-UK domiciled beneficiary may not be chargeable to tax on an offshore income gain arising in a non-resident settlement prior to 6 April 2008
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IFM13436Example showing how a UK resident but non-UK domiciled beneficiary may benefit from a ‘rebasing’ election
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IFM13438Example showing how a UK resident but non-UK domiciled beneficiary may not benefit from a ‘rebasing’ election
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IFM13440Transfer of assets abroad
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IFM13442Offshore income gains arising to certain non-resident companies
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IFM13444Application of other TCGA provisions