Offshore Funds: Distributor Status
06/06/1995
Query
Would an offshore fund qualify for certification as a distributing fund notwithstanding the fact that no distribution is made and the fund has a nominal level of income?
Decision
Yes, where the level of income does not exceed 1% of the average value of the funds assets held during the accounting period.
Income Tax
Schedule 19, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:5067/95