Hi
In general terms, we can advise that the disposal of an interest in a reporting fund by a UK resident which was previously a non-reporting fund, and where an election under Regulation 48 of Statutory Instrument 2009/3001 hasn’t been made, will give rise to an offshore income gain (OIG) where the full gain would be subject to income tax as miscellaneous income.
(
Offshore Funds,
The Offshore Funds (Tax) Regulations 2009 and IFM13414 &
Regulation 18).
We are unable to answer hypothetical questions and can only give general advise.
You may wish to seek professional advice if you require a more details answer.