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Posted Tue, 09 May 2023 12:53:53 GMT by zdanielz
Hi, I am considering investment in an off-shore fund which doesn't give interest or dividend. Specifically I am interested in investing in ZIVB - the underlying asset are VIX future contracts as described here: [Link removed - admin] Because of it's structure (and there are several similar funds [details removed] it does not produce any interest or dividend - gains can only be made by disposing (selling) of units at a higher cost than bought. Would gains in these kind of funds be taxed as Capital Gains (and taxed as such)? Thanks, 
Posted Tue, 16 May 2023 09:59:17 GMT by HMRC Admin 32
Hi,

A gain on the disposal of an interest in a non-reporting offshore fund will generally be charged to income tax as an offshore income gain. You can read more about the taxation of participants in offshore funds in our Investment Funds manual. The guidance on offshore income gains starts at IFM13400 onwards.  

IFM13400 - Offshore Funds: participants in offshore funds: the charge to tax on disposal of an interest in a non-reporting fund

Thank you.
Posted Tue, 16 May 2023 10:08:53 GMT by zdanielz
Thank you - just to be clear, any gains with this ETF will be not be due to interest, but prices of the underlying assets increasing. Is that still considered "disposal of interest"? there is no interest involved. Thanks again
Posted Mon, 22 May 2023 14:38:50 GMT by HMRC Admin 5
Hi

It is a gain if you are disposing of your 'interest' in the gain. This doesnt mean interest that has arisen. 

You can find guidance here IFM13410 - Offshore Funds: participants in offshore funds: the charge to tax on disposal of an interest in a non-reporting fund: overview

and subsequent links.

Thank you.

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