HM Treasury published on 22 February 2008 an outline of a proposed new tax regime for authorised investment funds (AIFs) that invest in non-distributing offshore funds. The new regime would aim to move the point of taxation from the AIF to its investors and to ensure that investors in the AIF are subject to broadly the same tax treatment as if they had invested directly in the underlying offshore fund.

The government intends to publish draft regulations containing the proposed tax rules in spring 2008.

The regime may be attractive to UK tax exempt investors seeking a tax efficient vehicle for investing in non-distributing offshore funds but appears less attractive from a tax perspective to UK tax paying individual investors.