PART 3REPORTING FUNDS AND THE TREATMENT OF PARTICIPANTS IN REPORTING FUNDS
CHAPTER 8THE TAX TREATMENT OF PARTICIPANTS IN REPORTING FUNDS
Tax treatment of the reported income of the fund in the hands of participants
Participants chargeable to income tax: transparent funds97
1
This regulation applies if—
a
a reporting fund is a transparent fund, and
b
some or all of the excess specified in regulation 94(2) is treated as income of a participant by virtue of that provision.
2
Any amount to which paragraph (1) applies is charged to income tax under Chapter 8 of Part 5 of ITTOIA 2005 as relevant foreign income within the meaning given by section 830 of ITTOIA 2005 M1 for the year of assessment in which the distribution is made, but sections 688(1) and 689 of ITTOIA 2005 do not apply.