Revenue Note for Guidance
747D Payment in respect of offshore funds
Where an investor (who is an individual) in an offshore fund receives a payment therefrom, (otherwise than on the disposal of all or part of his or her interest) then, if the amount of the payment is correctly included in a timely return, it will be liable to income tax at the relevant rate specified in Table 1 below: —
Chargeable event arising – |
Regular payment |
Non-regular payment |
PPIU – see section 739BA – applicable from 20 February 2007 |
Before 1 January 2009 |
Standard rate of income tax (20%) |
Standard rate of income tax (20%) plus 3% |
Standard rate of income tax (20%) plus 23% |
Between 1 January 2009 and 7 April 2009 |
Standard rate of income tax (20%) plus 3% |
Standard rate of income tax (20%) plus 6% |
Standard rate of income tax (20%) plus 26% |
Between 8 April 2009 and 31 December 2010 |
25% |
28% |
Standard rate of income tax (20%) plus 28% |
Between 1 January 2011 and 31 December 2011 |
27% |
30% |
Standard rate of income tax (20%) plus 30% |
Between 1 January 2012 and 31 December 2012 |
30% |
33% |
Standard rate of income tax (20%) plus 33% |
Between 1 January 2013 and 31 December 2013 |
33% |
36% |
Standard rate of income tax (20%) plus 36% |
Between 1 January 2014 and 31 December 2014 |
41% |
41% |
60% |
On or after 1 January 2015* |
41% |
41% |
60% |
* See additional Note following Table 2 below.
However, if the payment is not correctly included in such a return, it will be liable to income tax at the relevant rate specified in Table 2 below:—
Chargeable event arising – |
Not a PPIU |
PPIU – see section 739BA – applicable from 20 February 2007 |
Before 1 January 2009 |
Marginal rate (i.e. 20% or 41% as appropriate) |
Marginal rate (i.e. 20% or 41% as appropriate) plus 20% |
Between 1 January 2009 and 7 April 2009 |
Marginal rate (i.e. 20% or 41% as appropriate) |
Marginal rate (i.e. 20% or 41% as appropriate) plus 23% |
Between 8 April 2009 and 31 December 2010 |
Marginal rate (i.e. 20% or 41% as appropriate) |
Marginal rate (i.e. 20% or 41% as appropriate) plus 25% |
Between 1 January 2011 and 31 December 2011 |
Marginal rate (i.e. 20% or 41% as appropriate) |
Marginal rate (i.e. 20% or 41% as appropriate) plus 27% |
Between 1 January 2012 and 31 December 2012 |
Marginal rate (i.e. 20% or 41% as appropriate) |
Marginal rate (i.e. 20% or 41% as appropriate) plus 30% |
Between 1 January 2013 and 31 December 2013 |
Marginal rate (i.e. 20% or 41% as appropriate) |
Marginal rate (i.e. 20% or 41% as appropriate) plus 33% |
Between 1 January 2014 and 31 December 2014 |
41% |
80% |
On or after 1 January 2015 |
41% |
80% |
Note: With effect from 1 January 2015, the distinction between ‘correctly included’ and ‘not correctly included’ is removed for other than a PPIU, and, any payment, whether regular or non-regular, (excluding from a PPIU), will be liable to income tax at the rate of 41% (i.e. one percentage point higher than the higher rate of income tax (40%) that comes into effect from that same date).
A company carrying on a financial trade is taxed on any payment or gain arising from its investment at the corporation tax trading rate where the investment is part of its trading stock. Otherwise, the payment to a company is chargeable to tax under Case III of Schedule D.
Relevant Date: Finance Act 2019