# The Co-ownership Contractual Schemes (Tax) Regulations 2025, Regulation 49: Investments in non-reporting offshore funds: second case


(1) This regulation applies if a RIF has made an investment for its purposes in a non-reporting fund, but the conditions in regulation 48(2) are not met for an accounting period.
(2) The increase in fair value of the investment in the non-reporting fund in that period 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) Decreases in the fair value of that interest in earlier accounting periods may be set against the increase referred to in paragraph (2) to reduce the amount of the increase, but—
(a) not to below zero, and
(b) only to the extent that the decreases in fair value have not previously had the effect of reducing the amount of a fair value increase.
(4) The additional income is treated as arising on the information reporting date in respect of the accounting period in which the fair value increase arises.
(5) In this regulation “fair value” in relation to an interest in a non-reporting fund means the amount which, at the time the value is to be determined, is the amount for which the interest could be exchanged between knowledgeable and willing parties dealing at arm’s length.

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Source: https://www.legislation.gov.uk/uksi/2025/200/regulation/49 (the official version)
Page: https://openlegislation.uk/co-ownership-contractual-schemes-tax-regulations-2025/regulation-49
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.