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Offshore funds—background

B5.701 Offshore funds—overview

The offshore funds regime legislation is found in:

1. Ìý

   •ÌýÌýÌýÌý Taxation (International and Other Provisions) Act 2010, ss 354–363A, Pt 8, and

2. Ìý

   •ÌýÌýÌýÌý The Offshore Fund (Tax) Regulations 2009, SI 2009/3001 (as amended) (the Offshore Funds Regulations)

HMRC guidance is at IFM12100 onwards.

In addition, it was announced at Budget 2020 that the government would be carrying out a review of the UK funds regime, covering both tax and relevant areas of regulation. The government published a call for input on 26 January 2021 setting out the scope and objectives of the review and inviting stakeholders to provide views on which reforms should be taken forward and how these should be prioritised. The call for input ran until 20 April 2021 and following Autumn Budget 2021, the government published a summary of responses and the proposed next steps¹. These include making the taxation of authorised