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Where a fund to which, immediately before 1 December 2009, ICTA 1988, s 756A applied¹ becomes a non-reporting fund on 1 December 2009, a participant is treated as having an interest in a non-reporting fund at the beginning of the accounting period in which the 1 December 2009 falls². Any offshore income gain arising to a person on the disposal of an asset must be computed in accordance with the regulations relating to non-reporting funds but the whole period of ownership of the asset must be taken into account³.

A fund which, immediately before 1 December 2009, was a distributing fund for the purposes of ICTA 1988, ss 756A–764 (Pt XVII, Ch V) or a fund treated as a distributing fund in accordance with SI 2009/3001, Sch 1, Pt 4, para 3(3A), or, from 27 May 2011, the person who is assessed in respect of a gain of that fund, may apply to be treated as a distributing fund⁴ for the period of account overlapping