Taxes Consolidation Act 1997 section 747D

Payment in respect of offshore funds

Section 747D sets out the income tax and corporation tax rates that apply when a person with a material interest in an offshore fund receives a payment from that fund.

• Where an individual receives a payment from an offshore fund (other than on disposal of the interest), the income is taxed at 38%, or at 60% where the fund is a personal portfolio investment undertaking (PPIU).
• Where the offshore fund is a PPIU and the income is not correctly included in the individual's tax return, a penal rate of 80% applies.
• These rates override the normal income tax rate bands and apply on a self-assessment basis.
• Where the recipient is a company and the payment is not a trading receipt, the income is charged to corporation tax under Case III of Schedule D as untaxed investment income.