Use of Fund Reporting Date / Distribution Date for ERI in CGT Calculation and Income Reporting

Trying to clarify the treatment for Excess Reportable Income from Accumulation Units in an Approved Offshore Reporting Fund using HMRC “HS265 Offshore funds”. Firstly, I am assuming that the Reporting Date determines whether you are deemed to have received the ERI (not the Distribution Date)? So for a Fund with the following dates: Fund Reporting Date: 31/12/2022 Fund Distribution Date: 30/06/2023 For a Disposal Date of 20/12/2022 (Before the Reporting Date of 31/12/2022) there is no ERI as it was sold before the Reporting Date. For Disposal Date: 20/01/2023 (After Reporting Date but Before Distribution Date) 1) You have received ERI as it was held at the reporting date, even though the units were not held at distribution date. 2) Is it correct that the ERI increases base cost for CGT in 2022-2023 BUT the actual ERI (Foreign Interest) is reported in income in 2023-2024? So in effect - you use the Reporting Date for including ERI the CGT Disposal calc and the Distribution Date to report ERI as Income.

Hi,

If you dispose of your shares or units in a reporting offshore fund, you will be subject to Capital Gains Tax on any gain you realise. Any excess reported income which arose to you during the period in which you owned the shares or units can be deducted when calculating your capital gain. This ensures you are not subject to double tax on the excess reported income.  

For capital gains purposes, you would use the disposal date when calculating the gain.

Thank you.

Hi, Could you please look at my specific question on dates - where the Fund Reporting Date and Disposal Date is in one tax year, but the Fund Deemed Distribution Date falls into the following tax year (because it's 6 months later). i.e. It's possible that the ERI increases base cost for CGT in 2022-2023 BUT the actual ERI (Foreign Interest) is reported in income in 2023-2024. So in effect - you use the Reporting Date for including ERI the CGT Disposal calc and the Distribution Date to report ERI as Income. Thanks.

Hi JustCheck,
HMRC cannot comment on specifics on this form and you will need to contact us direct on 0300 200 3310 or via webchatc.
Thank you