Epstein File EFTA01452023: Offshore and Controlled (DS10)

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Epstein File EFTA01452023: Offshore and Controlled (DS10)

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This document contains regulatory guidance on the application of UK tax law to offshore funds, specifically the Taxation (International and Other Provisions) Act 2010 and the Offshore Funds (Tax) Regulations 2009. It addresses how these rules apply to investments made by funds in offshore entities and explains the tax treatment of controlled foreign companies for UK resident investors. The document outlines circumstances under which profits from controlled foreign companies can be apportioned to UK resident companies for corporation tax purposes.

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offshore controlled

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Excerpt 1

The Taxation (International and Other Provisions) Act 2010 and the **Offshore** Funds (Tax) Regulations 2009 ( together the "**Offshore** Fund Rules") may apply

Excerpt 2

to an investment made by the Fund in an "**offshore** fund".

Excerpt 3

**offshore** funds for such purposes.