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Hedge Fund X-Ray

What a hedge fund leaves a UK investor

Budget of 28 October 2026: a further two points on savings income from 6 April 2027 were announced, taking the rates to 24%, 44% and 49% if enacted. Figures for 2027/28 on this page still use the Finance Act 2026 rates of 22%, 42% and 47%. What the Budget changes for offshore bonds.

The full cascade of management fee, hurdle, high-water mark and performance fee, then UK tax on income and gains, then the gross return the fund would need for you to keep what you want.

By Eldar Edmond Grady, CEO, PPLI.com · Research checked 23 September 2026, model corrected 20 October 2026

The instrument runs in your browser and needs JavaScript. The method and the worked examples below are written out in full and read without it.
Context

The reported figure stops before your tax

A hedge fund reports its return net of its own fees. Your tax comes after that, and for a UK resident it depends on how the return arrives: income at the savings rate, realised gains at 24%, and gains on a non-reporting offshore fund taxed as income.

Inside a policy the tax layer is deferred, but only where the fund counts as permitted property or is picked by an insurer-appointed manager you do not direct; the manager's fees are due either way. Outside a policy the whole tax layer applies, and the instrument shows it year by year.

A worked case, hypothetical

£1,000,000, one year, 10% gross, 2 and 20

No hurdle. The fund pays its own fees first, so UK tax is measured on the £64,000 that is left, not on the £100,000 the strategy earned. One year, one position, the whole result taken as a gain on the units, the £3,000 annual exempt amount ignored: a narrow illustration, not a client result.

The same fund, three tax positions
Value after fees 1,000,000 + 100,000 − 20,000 − 16,000 = £1,064,000 Gain on the units, after the fund's fees £64,000 Reporting fund, CGT 24% on 64,000 tax 15,360 kept £1,048,640 Non-reporting fund, 45% on 64,000 tax 28,800 kept £1,035,200 Non-reporting fund, higher rate 40% tax 25,600 kept £1,038,400 Transparent fund: your share of the fund's own income and realised gains, as they arise 15,360 if the result is all gain; 28,800 if it is all interest at 45%

Choose the fund status in the instrument and it applies these rules. The gap between a reporting and a non-reporting fund here is £13,440 on one year and one position, and it grows with the gain. A fee you pay your own adviser is a separate cost: it comes from taxed money and reduces none of these figures.

The calculation

How the X-Ray works

The fee waterfall

Management fee on the opening value; performance fee on the profit after it, above the high-water mark and any hurdle (hard or soft).

Two kinds of fee

The management and performance fees are the fund's own costs. They reduce its value and its reported income, so everything that follows is measured after them. A fee you pay an adviser yourself comes out of taxed money and is not deductible; the instrument shows it on a separate line.

Tax, by fund status

A reporting fund is taxed each year on its reported income at the savings rate, and on the gain on the units at the CGT rate when the position is closed; the fund's own trading inside the portfolio is not taxed to you. A non-reporting fund is taxed only when the units are sold, on the whole gain at the savings rate, as an offshore income gain. A transparent fund is taxed on its own income and realised gains as they arise, at the savings rate and the CGT rate respectively.

Solving backwards

The required gross return is found by trying gross returns until the net result matches your target. It is the same model run in reverse.

Questions

Common questions

Are the fund's fees deducted before tax?

Yes. The fund pays its management and performance fees out of its own assets, so the reported income of a reporting fund, which starts from the fund's total comprehensive income in its accounts, and the gain on your units are both measured after them. What is not deductible is a fee you pay an adviser yourself: that comes from taxed money, and the instrument keeps it on a separate line. Until 20 October 2026 this page modelled the fund's fees as non-deductible, which overstated the tax and with it the case for holding the fund inside a policy. That has been corrected.

Which fund status should I choose?

HMRC publishes a list of reporting funds. If the fund is on it, choose reporting. If an offshore fund is not on it, choose non-reporting. Choose transparent for a fund that UK tax treats as a partnership or otherwise looks through, so that its income and gains are yours as they arise. If you are not sure, the fund's offering document or its administrator will say.

PPLI.com is not authorised by the Financial Conduct Authority and does not give personal advice. This is general information about UK law, not an invitation or inducement to enter into any insurance or investment contract. Policies issued by insurers outside the UK are not protected by the Financial Services Compensation Scheme (unless written through a UK branch).

Sources and authorities

The authorities this page relies on

HMRC helpsheet HS265

A gain on disposal of a non-reporting offshore fund is normally an offshore income gain, charged to income tax. A gain on a reporting fund is charged to capital gains tax. gov.uk, HS265

IFM12146 and IFM12524

An investor in a reporting fund is taxed on sums distributed and on the undistributed excess reported for each unit, and on the gain on the units when they are sold. The computation of reportable income starts from the fund's total comprehensive income under reg 63 of the Offshore Funds (Tax) Regulations 2009, so the fund's own expenses have already come off. gov.uk, IFM12146 gov.uk, IFM12524

Income tax, savings and dividend rates

Savings rates 20, 40 and 45% in 2026/27. Dividend rates 10.75, 35.75 and 39.35% from 6 April 2026. Savings rates of 22, 42 and 47% from 6 April 2027 (FA 2026 s.5), shown here only as a labelled option. gov.uk, rate changes

Capital gains tax rates

18 and 24% for disposals on or after 30 October 2024. Business Asset Disposal Relief at 18% from 6 April 2026. Annual exempt amount £3,000. gov.uk, CGT rates

Personal portfolio bonds, ITTOIA ss.516, 520 and 522

A policy is a personal portfolio bond if the holder, a connected person or someone acting for them can select the assets outside the permitted categories in s.520. At the end of each insurance year except the last, a deemed gain of 15% of premiums plus earlier deemed gains is taxed, with no top-slicing relief. legislation.gov.uk, s.522

IPTM7725 and IPTM7730

An insurer-appointed manager normally avoids personal portfolio bond status, but a mandate restricted so tightly that the policyholder's instructions in effect determine the assets is treated as selection by the policyholder. gov.uk, IPTM7730

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Eldar Edmond Grady
Author
Eldar Edmond Grady
CEO, PPLI.com
Checked against UK primary sources. The statutes, HMRC manual paragraphs and regulator pages cited are linked in the text so each statement can be read beside its basis.
Last updated: 20 October 2026
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