§ Mr. Skeetasked the Chancellor of the Exchequer when he expects to publish draft clauses on offshore and overseas funds and on life assurance policies issued by non-resident life offices; and whether he will be making any modifications to the proposals announced on 17 November 1983.
§ Mr. MooreWith my approval, the Inland Revenue is publishing draft clauses today.
We have considered carefully the representations we have received on both offshore and overseas funds and life assurance policies issued by non-resident life offices. We intend to make a number of modifications to the proposals set out in the Inland Revenue's statement of 17 November 1983. The changes on the life assurance side are incorporated in the draft clauses, and clarify the arrangements for expatriates. They also cover two new points. One is a minor technical amendment to paragraph 9(3) (a) of schedule 1 to the Taxes Act 1970. The other is to extend the new basic rate charge on gains from offshore non-qualifying policies to gains from capital redemption policies issued after midnight tonight.
As regards offshore and overseas funds, the modifications relate to the conditions which funds will have to satisfy if they are to obtain distributor status. They will make it easier for some types of fund, which would otherwise have genuine difficulties, to qualify as distributors. Although it has not been possible to embody the changes at this stage in the draft provisions we consider that it would be helpful to announce them now, and I have authorised the Inland Revenue to issue a statement giving details.