Residence of Offshore Funds - extending the scope of Section 363A Taxation Act 2010
The Government announced at Budget 2013 that it would consult on proposals to widen the scope of section 363A TIOPA. HM Revenue & Customs (HMRC) are asking for views on the scope of the extension.
Detail
Section 363A Taxation (International and Other Provisions) Act 2010 (‘TIOPA’) treats certain offshore funds as not resident in the UK if they are resident under the law of a Member State.
HMRC would like to hear in particular from tax practitioners, fund managers, representative bodies, administrators and other interested parties.
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