IFM13460 - Offshore Funds: investors in non-reporting funds: exceptions to the charge to tax: excluded indexed securities
Regulation 25(5) of SI 2009/3001
ITTOIA05/S433 explains the meaning of 바카라 사이트˜excluded indexed securities바카라 사이트™. They are outside the deeply discounted security rules, and are instead taxed under the capital gains rules. There is further guidance on excluded indexed securities in the Savings and Investment Manual.
Where an interest in an offshore fund would fall to be treated as an excluded indexed security, any gain arising on disposal will not be taxed as an offshore income gain, and the capital gains treatment is preserved.