F1PART 6AFUNDS INVESTING IN NON-REPORTING OFFSHORE FUNDS
CHAPTER 3Tax treatment of FINROFs and of participants in FINROFs
The charge to tax
Application of certain provisions of TCGA 199285O.
The following enactments have effect in relation to income tax or corporation tax in respect of income gains as they have effect in relation to capital gains tax or corporation tax in respect of chargeable gains—
(a)
section 2(1) of TCGA 1992 (persons chargeable to capital gains tax);
(b)
section 10 of TCGA 1992 (non-resident with a United Kingdom branch or agency);
(c)
section 10B of TCGA 1992 (non-resident company with United Kingdom permanent establishment).