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STOP PRESS: The remittance basis is abolished from 6 April 2025, although this only applies to foreign income and gains arising on or after that date. The remittance basis rules still apply to unremitted income and gains arising before that date but remitted later. The legislation is included in FA 2025. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.

An outline of the regime applying to offshore funds is discussed in the Offshore funds guidance note, and you are advised to read that guidance note first. It also explains what is meant by ‘reporting’ and ‘non-reporting’ funds.

Reporting funds can be divided into ‘opaque’ funds (also known as non-transparent funds), where investors are regarded as owning units in the fund rather than as owning precise fractions of the underlying assets, and ‘transparent’ funds, where the investor has a share of the underlying fund assets.

The fund manager should be able to tell the taxpayer whether the fund is opaque or transparent for tax purposes.

This guidance note