IFM12554 - Offshore Funds: Reporting Funds: computation of reportable income: transactions not treated as trading: introduction
Regulation 73 of SI 2009/3001
Chapter 6 of Part 3 of the Regulations provide certainty that specified transactions will not be treated as trading transactions for reporting funds that meet the 鈥榚quivalence condition鈥� at regulation 74, and the genuine diversity of ownership (鈥楪DO鈥�) condition at regulation 75 in that chapter. The list of applicable transactions (the 鈥榠nvestment transactions list鈥�) is contained in the Investment Transactions (Tax) Regulations 2014 鈥� regulation 80, see IFM12557.
The following pages provide further guidance on the conditions and scope of investment transactions.
Tax-transparent Funds
The 鈥榠nvestment transactions list鈥� does not apply to tax-transparent funds as the income of such funds arises directly to their investors (regulation 49(3)).