Onshore/offshore fund taxation nuances

An offshore fund's disposal treatment turns entirely on its UK reporting-fund status, under the Offshore Funds (Tax) Regulations 2009. A fund with UK reporting status is taxed like any UK-based collective on disposal: the gain is an ordinary capital gain, using the annual exempt amount and Capital Gains Tax rates. A fund WITHOUT UK reporting status is taxed completely differently on disposal — the entire gain becomes an "offshore income gain" and is taxed as income, at the investor's marginal income tax rate. There is no annual exempt amount, no CGT rates, and no CGT treatment at all for a non-reporting fund's disposal gain. This is a genuinely different mechanism from the onshore equity/bond fund distinction (which only affects how regular income distributions are taxed, not disposal gains) — here, reporting status changes how the DISPOSAL itself is taxed.