Section 747AA Treatment of certain offshore funds
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Amendments
Section 747AA inserted by Finance Act 2007 section 39(1)(b) as respects income arising or gains accruing on or after 20 February 2007.
Without prejudice to "offshore fund" having the meaning assigned to it by section 743 for the purposes of Chapter 4, where that Chapter does not apply to an offshore fund by virtue of subsection (2A) of section 747B, then Chapter 2 and section 747A shall not apply in respect of that offshore fund.
Can gains arising on a "personal portfolio" offshore fund qualify for CGT treatment?
Where a fund does not qualify as an offshore fund, because it is regarded as a "personal portfolio" fund (within section 747B(2A), gains arising from such a fund will also fail to qualify for CGT treatment (section 747A).
