Offshore funds survey

Offshore funds surveyGrant Thornton UK LLP June 2012

Contents

The research was conducted through a combination of telephone interviews and an on-line survey.

Respondent anonymity has been maintained to ensure that no comments, views or dates can be attributed to an individual or organisation.

This full report will be received by all those asked to participate in the survey. This will enable them to compare their own responses with those of other funds, managers and organisations.

2 Offshore Funds Survey

Contents

2 Contents

3 Introduction

4 Background

5 Summary of survey findings

The Survey

6-11 Observations

12 Practical issues – Applications

13-19 Practical issues – Reporting

20-23 Summary thoughts

24 Financial Services Tax/Contacts

Offshore Funds Survey 3

Intended audienceThis survey is designed and intended for individuals responsible for UK tax and compliance of offshore funds marketed to UK investors. A level of knowledge of the existing and previous tax rules relating to offshore funds is assumed, but where specific or detailed technical points are referred to further explanation is provided.

The new regimeThe new Reporting Fund (RF) regime came into effect on 1 December 2009. It replaces and is intended to simplify the previous UK Distributor Status (UKDS) rules applicable to offshore funds.

The purpose of the new regime from a tax perspective remains as before, i.e. to prevent conversion of income into capital gains by the rolling up of income offshore in a low tax environment and then realising this in capital form.

With the current differential between the UK capital gains and income tax rates, this is one of the ways HM Revenue & Customs (HMRC) seeks to prevent the avoidance of tax by UK taxpayers.

Funds which choose to be part of the RF regime are required to notify investors of income, as calculated under the regulations, for an accounting period. UK taxpaying investors must then report and pay tax on their share of this income regardless of actual distributions received. Actual distributions are not subject to further tax to the extent they do not exceed reported income allocations.

Investors realising investments in reporting funds may treat any gains arising on disposal as capital for tax purposes. Profits made on the disposal of non-reporting offshore funds are taxed as

income profits, albeit that losses remain as capital losses.

ImplementationAs with any new and complex regime, and as confirmed by the results of this survey, teething problems along the way cannot be avoided. The original RF regulations and accompanying guidance were released after a two year long consultation, and have subsequently been updated four times, the most significant of which was less than a year ago in May 2011. It seems likely that this will not be the last as more funds seek to join the new regime and raise new questions on issues that have not been addressed in the existing legislation or guidance.

The transitional provisions within the regulations allowed for distributing funds to delay entry into the new regime for one further accounting period following the accounting period containing 1 December 2009. Other funds, particularly those which in the past have had to operate reinvestment mechanics or which had holdings in other offshore funds, welcomed the ability to enter into the regime at an earlier stage.

With this in mind, and with the first annual reporting cycle now either complete or currently in progress, Grant Thornton decided to undertake an industry survey and produce a summary document, designed to facilitate discussions of the issues faced in complying with the new rules.

The questions asked in this survey cover a range of specific areas and tried to focus on the issues where we know a number of our clients and the wider industry have had comments and concerns.

The comments that we received confirmed that these issues which our clients face are also concerns for the wider offshore fund industry. The remainder of this document details the responses to the questions we asked and also allows for a number of conclusions to be drawn.

We would like to thank all participants who took part in this survey, without whose input this survey would not have been possible.

We hope you find this survey of interest and would be pleased to discuss further with interested parties.

Grant Thornton UK LLP Financial Services Tax TeamJune 2012

Introduction

Background

A total of 50 selected offshore fund providers and administrators were contacted to participate in this survey.

A wide spectrum of asset classes is represented by the survey participants. Some respondents represent small funds, some are very large, multi-fund managers and some are from the middle ground. In addition, a number of offshore fund administrators were contacted to gather their views.

Each participant was informed of the objectives of the research survey and the survey questionnaire. The survey questionnaire contained 23 specific questions which were grouped under four headings:

• Observations• Practical issues – Applications• Practical issues – Reporting• Summary thoughts

It was initially estimated that the survey conversation would take 20 minutes, but it was found that in a number of cases people preferred to complete the survey electronically. Where conversations did take place the discussion took nearer three quarters of an hour, with the longest lasting an hour and a half. This is clearly indicative of the richness of the responses and the extent of the consideration given to compliance with the regime. The time commitment from all involved in this process is very much appreciated.

Discussions took place with Chief Financial Officers, Chief Operating Officers, Product Managers and others closely involved in the offshore funds regime. Respondents were forthcoming and candid in their views expressed. Selected anonymised comments are used throughout this document to emphasise a point or to support conclusions reached by Grant Thornton.


Summary of survey findings

The original aim of the regulations was to remove impediments from the UK tax regime for multi-tiered fund structures, by simplifying the operation of the offshore funds tax regime and providing more certainty to UK investors and funds. Although the removal of the 5% test for investment in other non-qualifying offshore funds goes a long way to achieving this aim, it is questionable whether the requirements of the RF regime are simpler than those of the UKDS rules.

SimplificationPerhaps unsurprisingly, only 22% of respondents think that the new RF regime is simpler than the previous UKDS regime. That said, for the majority of people we have spoken to who have now completed their first year of reporting, the process appears to have run smoothly.

Income distributionWhen asked whether or not having to distribute income has influenced the decision to join the regime, only 41% of respondents felt that it had. However, of those that felt that it had not, a number acknowledged the ability now for accumulation funds to apply for RF status as being a welcome development, potentially enabling some hedge fund promoters to now market to the UK without adverse UK tax consequences for investors.

Administration costs52% of respondents have seen administration costs increase, with the operation of equalisation and increased reporting duties being the main reason behind these increases.

ReportingThe majority, 70%, of respondents would like to see a pro-forma template introduced to allow a standardised form for reporting. It is believed that this would provide consistency amongst reports helping to improve investor understanding. Worryingly, but perhaps unsurprisingly, only 19% of respondents feel that investors have a good understanding of the information they are provided with.

In line with expectations, 62% of respondents are using a website as a means of reporting to investors. However, there is concern that information is not reaching the underlying investor, especially where nominee accounts are used or where investors do not have access to the internet.

EqualisationAlthough only 23% of respondents have had difficulties with the operation of equalisation, most respondents highlighted equalisation as being an added complexity for which they would like to see further guidance from HMRC. Surprisingly, given the last man standing issue, only 22% of respondents have changed their approach to equalisation.


Observations

“We now have to prepare RF calculations for funds that previously did not require it”

Fig 1: New definition of an offshore fund

0 20 40 60 80 100

Yes 17%

Not applicable83%


Q. The new definition of an offshore fund has resulted in many more funds coming within the new regime. Do you have funds which fell outside the old definition but now come within the new definition of an offshore fund, and if so, how has this impacted your business?

Grant Thornton comment:A new tax definition of an offshore fund came into effect on 1 December 2009, potentially resulting in more funds coming into the regime for the first time and therefore having to consider the impact of the regulations.

Most respondents (83%) felt that this had little impact on their business.

The new definition of an offshore fund provides a new characteristics driven definition of a ‘mutual fund’ (S.355 & S.356 TIOPA 2010). In the run up to the introduction of the new rules it had perhaps been anticipated that a number of funds previously excluded from the old definition of an offshore fund would be caught by the new rules. The response to the question indicates that this is not necessarily the case.

As an aside (although untested by this survey) it would perhaps be interesting to assess how many funds and managers outside of the old UKDS regime have undertaken a review to assess the applicability of the RF regime across their full range of products.

For those answering positively, the inclusion now of some closed ended funds has created additional work.


“Clients are taking the opportunity not to distribute as a way of entering the regime, and are now marketing heavily in the UK”

Fig 2: Income distribution

0 10 20 30 40 50 60

Yes 41%

No 59%

Q. The new RF regime facilitates funds not having to distribute their income. Has this influenced your decision for funds to join the new regime?

Grant Thornton comment:The new rules makes RF status more accessible to funds which had previously been unable or unwilling to satisfy the UKDS requirements.

A significant number of respondents considered the introduction of the new rules as a reason to bring in funds which had previously been excluded.

This is supported by what is known about the wider market. Since the inception of the new regime HMRC’s data shows that there has been an approximate 60% increase in the number of reporting funds registered compared to the number of funds registered for UKDS. A number of funds have taken the opportunity to launch new share classes while the removal of the 5% test has allowed more fund of fund structures to enter the regime.

In terms of respondents answering no to this question, a number cited the potential for ‘dry tax charges’ (investors being assessed to tax on a reported income figure and not having the associated distribution to pay the tax) as a reason for not bringing more products within the scope of the new rules.

The point made by respondents is very valid where investment strategy gives rise to significant income streams. However, where capital growth is the main investment driver, with only minimal income arising, it seems likely that funds in this position will have chosen to accept a degree of administrative work in return for the perceived benefit RF status brings. This perhaps indicates one of the reasons why the take up of the new regime has been so high.

Observations


Q. Where you have funds that have now decided to join the RF regime but did not previously have UKDS, despite being classified as offshore funds, have you considered retrospective applications for UKDS to potentially help mitigate tax liabilities of UK investors?

Grant Thornton comment:HMRC has, in the past, allowed retrospective applications for UKDS by funds which have not previously been distributing. This is often seen where funds have little or no income and the extra administration of being part of the regime going forwards was seen as an acceptable trade-off for the associated investor’s tax benefits. As many readers will be aware, without a specific election by an investor, a fund must have held UKDS or have been part of the RF regime for an investor’s entire period of ownership in order to ensure capital treatment on disposal.

With the introduction of the RF regime it had been anticipated that some funds would join the regime and bring older periods into UKDS by making retrospective applications. One particular respondent to the survey confirmed that their organisation has made a number of retrospective applications for long only, non-trading hedge funds.

The results support this hypothesis in that 32% of survey respondents have considered making retrospective applications.

Fig 3: Retrospective UK Distributor Status applications

Yes 32%

No29%

Not applicable39%

“We now have in excess of 500 share classes registered as reporting funds”

Fig 4: Applications for new products

0

10

20

30

40

50

Yes 24%

No35%

Not applicable41%


Q. Has the new regime facilitated making RF applications for products which you were previously unable to obtain UKDS for, and if so, what types of products?

Grant Thornton comment:The RF regime has opened up the opportunity for funds and products to enter into the regime where before they were unable to do so due to restrictions imposed under the old regulations.

The removal of the requirement to distribute and the 5% investment restriction are welcome developments, and has led to both accumulation shares and some hedge funds now joining the regime. There has also been a significant increase in the number of fund of fund structures joining the regime, although a number of respondents have experienced difficulties in collating the necessary information from underlying funds.

Fig 5: Marketing assistance

0

10

20

30

40

50

60

Yes 17%

No59%

Not applicable24%

Q. To assist with marketing, have you applied for RF status for funds which strictly do not need the status, for example, transparent funds?

Grant Thornton comment:Certain fund types, for example some foreign unit trusts and Fonds Commun de Placement, are tax transparent for income purposes but opaque for capital gains purposes, and are therefore within the new definition of an offshore fund. However, even if the fund chooses to be a non-reporting fund, it is possible for it to still be excluded from potential offshore income gains treatment provided they meet certain conditions. As such, there may be no advantage to these funds being in the regime, although some providers have nevertheless sought to apply for RF status in respect of these funds.

Comments from some respondents indicate that the marketability of new products is improved if membership of the RF regime can be shown even if it is perhaps not needed. This could well be driven by less sophisticated investors or those with strict investment due diligence checklists.

Observations

“We have applied for good non-reporting status for a number of funds”


Fig 6: Administration costs

0

10

20

30

40

50

60

Yes 52%

No38%

Not applicable10%

Q. Have you seen administration costs increase as a result of complying with the new regime?

Grant Thornton comment:Owing to the increased requirements to provide information to both HMRC and investors it was anticipated that administrative costs would increase under the new regime.

Comments from respondents indicate that the RF regime is seen as significantly more complex than UKDS. Specific areas mentioned which have added complexity and therefore costs are effective yield calculations, collation of information for fund of funds and equalisation.

In addition the number of non-UKDS funds which have now joined the RF regime will have increased overall costs for larger managers and administrators with wide portfolios of products.


Practical issues - Applications

“More information required on derivatives and series share classes”


Q. If you have had an initial RF application rejected, what were the stated reasons and the ultimate outcome?

Fig 7: Application rejected

0 20 40 60 80 100

Not applicable100%

Yes0%

Fig 8: Further information

0 20 40 60 80 100

No86%

Yes14%

Q. Have you been asked by HMRC for further information for either the initial application or the subsequent reports, and if so, what further information was required?

Grant Thornton comment:Managers of offshore funds are now able to obtain forward looking certification of a fund as a reporting fund which will continue to apply until the fund chooses to leave or is removed from the regime.

Respondents commented that HMRC has requested further information to asses initial applications in limited circumstances, these being where derivatives were being used and series of share classes being operated. However, in our sample no legitimate applications had actually been refused by HMRC.


Practical issues - Reporting

Fig 9: Reportable income calculations and reports

0 20 40 60 80 100

Yes 81%

No 19%

Q. Have reportable income calculations and reports for investors now been prepared for your funds?

Grant Thornton comment:The new rules came into effect on 1 December 2009, meaning that the majority of funds have now prepared, or are in the process of preparing their first reportable income calculations.

However, there are still some funds that were already certified under the UKDS regime which have elected to use the transitional provisions to continue to be certified as distributing funds for as long as possible. The reason cited for delaying entry into the new regime is the perception that the UKDS regime is simpler. The requirement to report 100% of income rather than 85% has also been a factor.

Fig 10: Pro-forma template

0 10 20 30 40 50 60 70 80

Yes 70%

No 22%

Not sure 8%

Q. Would you like to see a pro-forma template to allow a standardised form for reporting?

Grant Thornton comment:The issue of a standardised form of reporting has been raised with HMRC, who has stated that it has no objection in principle. However, HMRC is also wary of being too prescriptive and suggest that an industry-led tool solution would seem appropriate.

Respondents to the survey were very much in favour of standardised reporting, however the complexity and variety of offshore funds would require an extremely sophisticated ‘one size fits all’ type reporting programme. Respondents acknowledged this, and a number stated that although they liked the idea in principle, they could see how in practice this would not be easy to implement.

“Difficult to implement with different options for equalisation”


Fig 11: Format of report

Website 62%

Individual letter to investor

19%

Individual email to investor

12%

Other 7%

Q. In what format are you making your report to investors available?

Grant Thornton comment:Reporting funds are required to make a report available to each investor who is resident in the UK (or which is a reporting fund) within six months of the end of the reporting period.

Clearly, the majority of respondents favour the dissemination of information via the internet given the saving in cost and administration this represents. Smaller organisations may tend to use a variety of other communication methods suited to the needs of their investors.

Whilst the internet was clearly the method of choice for the majority of those we spoke to, a number of respondents expressed concern as to whether the relevant information was ending up in the hands of the underlying investor, especially where nominee accounts were being operated.

Although HMRC is sympathetic to the industry’s concerns, it has expressed the view that to the extent that the fund is aware that the method of delivery does not achieve the required outcome, then it is the fund’s responsibility to consider whether the information should be supplied in a different format.

“My concern is what happens to those without internet access”



Fig 12: Investor understanding

0

10

20

30

40

50

Yes 19%

No 31%

Not sure 50%

Q. Do you feel that investors have a good understanding of what the information means and what they are required to do with it?

Grant Thornton comment:Reports to investors must inform investors of the amount actually distributed, the excess of the amount of the reportable income over the amount actually distributed, and where applicable, the amount of equalisation per unit. There is concern that non-professional investors will not fully understand the implications of the reports.

Clearly, the fact that only 19% of respondents felt that their investors actually understood the information that they were being provided with, suggests that managers could potentially be doing more to educate their investors on what the information means.

Funds who tried to address this at the outset, by educating their professional intermediaries as to the implication of the new rules, now feel that this has been particularly beneficial. However, there is still an overriding concern that there is a gap between the sophisticated and less sophisticated investor.



Fig 13: Equalisation

0 5 10 15 20 25 30 35

No equalisation 31%

Income adjustments on basis of reported income 4%

Equalisation 19%

Full equalisation 27%

Income adjustments on basis of accounting income 0%

Different funds using different methods 19%

Q. Are you operating equalisation, and if so, what method?

“I don’t believe you should be allowed to operate without equalisation. It should be mandatory”


Fig 14: Equalisation difficulties

0 10 20 30 40 50

Yes 23%

No 46%

Not applicable 31%

Fig 15: Approach to equalisation

0 10 20 30 40 50 60 70 80

Yes 22%

No 78%

Grant Thornton comment:The new regulations give a fund five options regarding the operation of equalisation. The results show that there does not appear to be one preferred method, with different funds choosing different methods.

The overriding reason behind these different methods being adopted was the fact that some funds are operationally able to operate equalisation while others are not currently able to do so. Our observation of responses indicates that certain jurisdictions are more accustomed to operating equalisation than others, and have been doing so for a number of years.

A number of funds and administrators have encountered various issues ranging from operational difficulties to problems with accounting under overseas GAAPs. Hedge funds also have to deal with performance fee equalisation to add to the complexities.

Although not necessarily reflected in the results, in our experience the need to address the ‘last man standing’ issue has led to more income generating funds operating equalisation under the new RF regime. In addition, improved administration systems now allow equalisation to be operated where it wasn’t before due to operational constraints.

Q. Are you aware of any difficulties that have arisen in the operation of equalisation or in doing the income adjustments?

Q. Have you changed your approach to equalisation since the introduction of the RF regime, and if so, why?

“A practical / pragmatic solution was agreed with HMRC”

“Addressing the ‘last man standing’ issue”



Fig 16: Split between share classes

0

20

40

60

80

100

Yes 4%

No 85%

Not sure 11%

Q. Have your funds had any difficulties obtaining underlying information relating to the split of income/expenses between share classes? If so, please explain how you overcame these difficulties.

Grant Thornton comment:Each share class of an offshore fund is now considered to be an offshore fund in its own right. Although most administrators are now able to provide a split of income and expenses across the different share classes there are still instances where funds are having difficulties obtaining the relevant information. In these instances, HMRC has stated that it is likely to have no issue in the income/expenses being allocated across the share class based on the Net Asset Value of the share classes, as long as it produces a reasonable outcome.

Fig 17: Reportable income from offshore funds

0

10

20

30

40

50

Yes 16%

No 36%

Not applicable48%

Q. If your funds have holdings in other offshore funds, have they experienced any issues obtaining the reportable income figures from those funds?

Grant Thornton comment:The abolishing of the investment restriction under the previous regime has made it easier for funds of funds to achieve certification as reporting funds. However, there is the additional administrative complexity of determining the relevant income to be recorded where funds of funds are invested in a wide variety of reporting and non-reporting funds.


“Only problem is series accounting costs more”

Fig 18: Series accounting

0 20 40 60 80 100

Yes 4%

No 15%

Not applicable 81%

Q. Where share classes operate various series, is reporting in these instances a problem in practice? What problems do you face in this area?

Grant Thornton comment:A large number of funds, particularly in the hedge fund industry, issue units in series. Historically, series tended not to be an issue under the UKDS regime, but with the increase in hedge funds in the RF regime there has been concern about the potential for increased administrative complexity if each series is treated as a separate fund, as is strictly required.

HMRC has confirmed that where series are collapsed into one share class at the end of a reporting period only one figure of reportable income is required for that share class, thereby reducing the burden on funds. In other cases, however, separate calculations are currently still required.

The high level of not applicable responses probably reflects the fact that although common for hedge funds, series accounting is not so common with the total population of funds.


Summary thoughts

Fig 19: Complexity of regime

0 10 20 30 40 50

Less 22%

More 33%

Not sure 45%

Q. Do you believe that the new RF regime is more or less complicated than the old UKDS regime, and can you give reasons why?

Grant Thornton comment:The new regime came into effect on 1 December 2009, and as such the industry is still getting used to the regime. Teething problems are inevitable, but it is hoped that with time the new regime will be a favourable improvement, removing some of the restrictions imposed under the previous regime and providing more certainty to investors.

The one clear issue that people do have is with the operation of equalisation, and the complexities that it brings.

“The rules are simply more complicated, especially on equalisation”


Fig 20: HMRC guidance

0

5

10

15

20

25

30

35

40Yes 37%

No 37%

Not sure 26%

Q. Is the HMRC guidance detailed enough? What other areas would you like to see covered in the guidance?

Grant Thornton comment:The original guidance has recently been updated to incorporate the amending regulations that came into place on 27 May 2011. Whilst the guidance is useful in a number of areas it is still felt that more detail could be given in certain areas, especially regarding equalisation and the adjustments required to arrive at reportable income.

HMRC has acknowledged that further updating will be required. It is early days under the new regime and practical problems are still arising that will lead to further guidance being published. In the interim, HMRC has indicated that it plans to maintain a Q&A page for issues not covered in the current guidance.

Fig 21: Other jurisdictions

0

10

20

30

40

50

60

70

80

Yes 4%

No 69%

Not applicable 27%

Q. How do the RF rules compare to other jurisdictions where you have to report, for example Germany? Are the UK’s rules more complex?

Grant Thornton comment:As can be seen from the opinions expressed in Figure 21, the resounding indicative belief is that the UK’s RF regime is far less complex than that of Germany, as well as Italy, Austria and the US. However, it was also not considered to be the most straightforward, especially under the new regulations.

Summary thoughts

Fig 22: Standardised approach across Europe

0 10 20 30 40 50 60

Yes 52%

No 30%

Not sure 18%

Fig 23: Exclude certain funds

0 10 20 30 40 50 60 70 80

Yes 27%

No 12%

Not sure 61%


Q. Do you believe a standardised approach to investor reporting across Europe should be pursued? If yes, do you have any thoughts on how this could be achieved?

Grant Thornton comment:Although half the respondents believe that it is a good idea to standardise reporting across Europe, most doubted that it could be practically implemented unless fiscal unity is achieved.

Q. Do you believe the definition of an offshore fund should be amended to exclude certain funds which are required by their home regulator to distribute all income, for example, certain US funds?

Grant Thornton comment:Certain funds are required by regulation to distribute all their income to investors, eliminating any risk of them rolling up income offshore. For these funds, complying with the UK’s offshore fund rules is an administrative and costly burden that adds no real value to the fund or to HMRC.


“The investment industry across the whole EC should have its own reporting standard relevant to Collective Investment Schemes”

© 2012 Grant Thornton UK LLP. All rights reserved.

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Our Financial Services Tax teamThis survey was conducted by the Financial Services (FS) Tax team at Grant Thornton. Our FS Tax team comprises dedicated specialists supported in the UK by the wider multi-disciplinary Financial Services Group of which the tax team is part.

Our advice to clients is based on experience and knowledge of the very specific tax issues facing the industry. We are members of The Association of Investment Companies (AIC), the Alternative Investment Management Association (AIMA) and the Investment Management Association (IMA). We are contributing authors to Tolley’s Taxation of Collective Investment, Tolley’s Corporation Tax and provide thought leadership through regular publications and presentations.

Our team advise clients across the FS sector, and have a particular specialism in asset management. We advise funds, their managers and principals and related businesses on all aspects of UK and international tax compliance and planning.

Should you wish to discuss any issues raised by this survey or any other tax matters please do not hesitate to contact the authors:

Mark FieldenDirectorT +44 (0)20 7728 2783E [email protected]

Tim RussellManagerT +44 (0)20 7865 2187E [email protected]

Dana Ward Partner T +44 (0)20 7728 3316 E [email protected]

Anne Stopford Director T +44 (0)20 7865 2285 E [email protected]

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