Following the introduction of the Offshore Funds (Tax) Regulations 2009, some concerns about the operation of specific rules have been raised.
The most immediate relates to funds which operate equalisation on accumulation units.
HMRC have announced they will issue draft legislative material by the end of 2010 showing how such funds will calculate reported income. The department said it intends to address various other issues in early 2011.
The Government will make a statutory instrument, to amend the 2009 regulations, in the spring, when funds reporting on periods already ended at that time will have the option to use the new equalisation rule in calculating reported income.