IFM14260 - Taxation of investment trusts: Interests in offshore non-reporting funds: Income gains realised by investment trusts

Where an investment trust disposes of interests in offshore non-reporting funds (‘NRF’) any gains are taxed as income and so are subject to corporation tax in accordance with regulations 17 and 18 of SI 2009/3001 (the Offshore Funds (Tax) Regulations 2009 (see IFMXXXX for further details relating to offshore funds). There are exceptions to this rule for:

• Certain interests in NRFs where the investment trust has treated the investment as if it were a reporting fund (see IFM14264); and
• Certain indexed tracking funds (see IFM14266)