PART 2THE TREATMENT OF PARTICIPANTS IN NON-REPORTING FUNDS
CHAPTER 2CHARGES TO TAX ON PARTICIPANTS IN NON-REPORTING FUNDS
Application of TCGA 1992
Application of section 13 of TCGA 199224
1
Section 13 of TCGA 1992 M1 (chargeable gains accruing to certain non-resident companies) applies for the purposes of this Part with the following modifications.
2
The section applies as if—
a
for any reference to a chargeable gain there were substituted a reference to an offshore income gain; and
b
for any reference to anything accruing there were substituted a reference to it arising (with similar references being read accordingly).
3
The section applies as if, in subsection (5), paragraphs (b) and (c) were omitted.
4
The section applies as if, in subsection (7), for the reference to capital gains tax there were substituted a reference to income tax or corporation tax.
5
The section applies as if subsection (8) were omitted.
6
If this regulation applies, the person to whom the offshore income gain arises is treated as the person making the disposal.
7
To the extent that an offshore income gain is treated, by virtue of this regulation, as having accrued to any person resident F1... in the United Kingdom, that gain shall not be deemed to be the income of any individual for the purposes of Chapter 2 of Part 13 of ITA 2007 (transfer of assets abroad).