SCHEDULES
SCHEDULE 22Offshore funds
Part 2Application of TCGA 1992 to offshore funds
Making an election
16
1
An election under paragraph 15 must be made—
a
for capital gains tax purposes, by being included in a relevant return under TMA 1970, and
b
for corporation tax purposes, by being included in a relevant company tax return.
2
A return under TMA 1970 is relevant if it is for—
a
the tax year in respect of which the election is made, or
b
a subsequent relevant tax year.
3
A company tax return is relevant if it is for—
a
the accounting period in respect of which the election is made, or
b
a subsequent relevant accounting period.
4
The references in sub-paragraph (1) to an election being included in a return include an election being included by virtue of an amendment of the return.
5
An election under paragraph 15 is irrevocable.