{
  "url": "https://openlegislation.uk/offshore-funds-tax-regulations-2009/regulation-21",
  "json_url": "https://openlegislation.uk/offshore-funds-tax-regulations-2009/regulation-21.json",
  "legislation": "uksi/2009/3001",
  "legislation_title": "The Offshore Funds (Tax) Regulations 2009",
  "legislation_url": "https://openlegislation.uk/offshore-funds-tax-regulations-2009",
  "path": "regulation/21",
  "kind": "regulation",
  "number": "21",
  "heading": "Application of transfer of assets abroad provisions",
  "text": "(1) Chapter 2 of Part 13 of ITA 2007 (transfer of assets abroad) applies in relation to an offshore income gain arising to a person resident or domiciled outside the United Kingdom as if the offshore income gain were income becoming payable to the person.\n(2) Income treated as arising under that Chapter by virtue of paragraph (1) is regarded as “foreign” for the purposes of section 726, 730 or 735 of that Act.\n(3) Paragraph (1) does not apply in relation to an offshore income gain if (and to the extent that) it is treated, by virtue of regulation 24, as arising to a person resident ... in the United Kingdom.\n(4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .\n(5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .\n(6) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Words in reg. 21(3) omitted (6.4.2013) by virtue of The Income Tax (Removal of Ordinary Residence) Regulations 2013 (S.I. 2013/605), regs. 1, 7(3) (with reg. 2(a))"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Reg. 21(4)-(6) omitted (retrospective and for the tax year 2025-26 and subsequent tax years) by virtue of Finance Act 2026 (c. 11), s. 52(1)(b)(4)"
    },
    {
      "type": "M",
      "label": "M1",
      "text": "Section 726 was substituted by paragraph 165 of Schedule 7 to the Finance Act 2008; section 730 was substituted by paragraph 167 of Schedule 7 to the Finance Act 2008; and section 735 was substituted by paragraph 169 of Schedule 7 to the Finance Act 2008."
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2009/3001/regulation/21",
    "retrieved_at": "2026-10-29T03:01:48.652414+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}