The Authorised Investment Funds (Tax) (Amendment) Regulations, SI 2011/244, amend the Authorised Investment Funds (Tax) Regulations, SI 2006/964, and the Offshore Funds (Tax) Regulations, SI 2009/3001, in order
(i) to permit AIFs investing in ‘non-reporting’ offshore funds to treat those investments as investments in ‘reporting’ funds where they have sufficient information to compute the reported income, and
(ii) to increase the proportion of funds that an AIF may invest in other non-reporting funds before the AIF is treated as being primarily a fund investing in non-reporting offshore funds.
Following consultation, the government has taken action to ensure that the tax rules fit with modern business practice, the Treasury said. The first change will ‘better align’ the competitive position of AIFs with offshore reporting funds. Draft regulations published last October have been amended ‘to allow for additional operational flexibility’.
The Authorised Investment Funds (Tax) (Amendment) Regulations, SI 2011/244, amend the Authorised Investment Funds (Tax) Regulations, SI 2006/964, and the Offshore Funds (Tax) Regulations, SI 2009/3001, in order
(i) to permit AIFs investing in ‘non-reporting’ offshore funds to treat those investments as investments in ‘reporting’ funds where they have sufficient information to compute the reported income, and
(ii) to increase the proportion of funds that an AIF may invest in other non-reporting funds before the AIF is treated as being primarily a fund investing in non-reporting offshore funds.
Following consultation, the government has taken action to ensure that the tax rules fit with modern business practice, the Treasury said. The first change will ‘better align’ the competitive position of AIFs with offshore reporting funds. Draft regulations published last October have been amended ‘to allow for additional operational flexibility’.
