# The Co-ownership Contractual Schemes (Tax) Regulations 2025, Regulation 47: Investments in reporting offshore funds


(1) This regulation applies if a RIF has made an investment for its purposes in a reporting fund.
(2) The excess, if any, of the reported income of the reporting fund in respect of the investment over the amount distributed by the reporting fund in respect of that investment is treated for income tax and corporation tax purposes as additional income of the participants in the RIF in proportion to their rights in the RIF.
(3) If the reporting fund does not make a report available in accordance with regulation 90(5) of the 2009 Regulations—
(a) the operator of the RIF must estimate the amount of excess (if any) of the reportable income of the reporting fund in respect of the investment over the amount distributed by the reporting fund in respect of that investment, and
(b) the estimated amount is treated for income tax and corporation tax purposes as additional income of the participants in the RIF in proportion to their rights in the RIF.
(4) Where paragraph (3) applies, in the first accounting period in which the operator has sufficient information to accurately determine the amount of any excess estimated under that paragraph, the operator must make any necessary corrections by adjusting the estimated amount for that accounting period.
(5) The additional income is treated as arising on the information reporting date in respect of the accounting period in which the excess is treated as made under the 2009 Regulations.

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Source: https://www.legislation.gov.uk/uksi/2025/200/regulation/47 (the official version)
Page: https://openlegislation.uk/co-ownership-contractual-schemes-tax-regulations-2025/regulation-47
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.