Revenue eBrief No. 40/17

29 April 2017

Offshore funds regime

Since 1990, interests in offshore companies, offshore unit trusts and offshore co-ownerships (known as "offshore funds") have been subject to a specific tax regime. The tax treatment on income from these offshore funds, or gains on the disposal of an interest in these offshore funds, depends on a number of factors.

Revenue have updated two Tax and Duty Manuals to provide greater clarity on the operation of the offshore funds regime.

  • Tax and Duty Manual Part 27-02-01 provides details on the regime as a whole, and includes a number of decision trees to determine whether or not an offshore investment is subject to the offshore funds regime. 
  • Tax and Duty Manual Part 27-04-01 looks specifically at offshore funds located in the EU, the EEA or OECD member states with whom we have a double tax agreement.