Contractual based investment funds - Mazars - United Kingdom
Contractual based investment funds
From 1 April 2010, an option introduced in the Finance Act 2009 for corporate investors in offshore contract based funds such as Luxemburg FCPs and Irish CCFs will become compulsory. Under the rule, companies can ignore gains realised on the underlying fund portfolios in their corporation tax returns. Instead they must treat their participations in those funds in the same way as shares in a company or an investment in a unit trust and calculate chargeable gains and losses arising on disposals of those participations.
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The Government has now announced its intention to launch a working group to consult with industry on whether establishing a tax transparent UK based contractual fund vehicle similar to the Luxembourg or Irish model would be beneficial for the UK. The aim would be to introduce tax legislation in the Finance Bill 2011.
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