Introduction Summary
1.Section 44 and Schedule 22 provide for a new definition of an “offshore fund” to be used in tax legislation and, in particular, in regulations to be made under section 41 of the Finance Act (FA) 2008. The Schedule also provides for interests in certain “offshore funds” within the new definition to be treated as assets of the investors for the purposes of tax on capital gains (with the consequence that the underlying assets will no longer be treated as assets of the investors).