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Where a reporting fund is not a transparent fund, for example an open-ended investment company (see INTM180030 for a list of whether particular entity types are transparent or opaque), any excess, if any, of reported income over distributions made is treated as an additional distribution made to participants in proportion to their rights on the fund distribution date (see B5.717), or on such earlier date as the reported income in respect of that reporting period is recognised in the participant's accounts¹. For non-transparent funds the excess, if any, of reported income over the income of the fund is treated as additional income of the participant in proportion to their rights². However, these excesses does not include income relating to rights in certain existing holdings acquired before 1 December 2009³. The rights are those to which SI 2009/3001, reg 30 applies, see B5.706.

If a participant disposes of an interest in a reporting fund in a reporting period and TCGA 1992, s 106A (see C2.706) applies for capital gains purposes to identify any