# The Offshore Funds (Tax) Regulations 2009, Regulation 97: Participants chargeable to income tax: transparent funds


(1) This regulation applies if—
(a) a reporting fund is a transparent fund, and
(b) some or all of the excess specified in regulation 94(2) is treated as income of a participant by virtue of that provision.
(2) Any amount to which paragraph (1) applies is charged to income tax under Chapter 8 of Part 5 of ITTOIA 2005 as relevant foreign income within the meaning given by section 830 of ITTOIA 2005 for the year of assessment in which the distribution is made, but sections 688(1) and 689 of ITTOIA 2005 do not apply.

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Source: https://www.legislation.gov.uk/uksi/2009/3001/regulation/97 (the official version)
Page: https://openlegislation.uk/offshore-funds-tax-regulations-2009/regulation-97
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.