Excess reportable income is taxed in a tax year most people would not guess
The rule is six months, and six months moves the charge across the 5 April line more often than not. Across 11,896 published records, 54.1% fall due in a later tax year than the one their reporting period ended in.
The rule
Regulation 94 of SI 2009/3001 treats the excess as an additional distribution, and then fixes the date:
"In these Regulations the 'fund distribution date' for a reporting period of a reporting fund means the date six months following the last day of the reporting period." The Offshore Funds (Tax) Regulations 2009, reg 94(4)
Two consequences that catch people, both straight from the text:
- It is the fund's period end that decides who is charged, not the distribution date. Reg 94(3) treats the excess as made "to participants holding an interest in the fund at the end of the reporting period". Sell in February, and you can still be taxed in June on income from a fund you no longer own.
- The fund has until that same day to publish the number. Reg 90(5) gives the fund "a period of six months beginning with the day immediately following the final day of the reporting period". Reg 90(2)(c) says publishing it "on a website accessible to relevant participants and to HMRC" discharges the duty. The report can legally appear on the day the income arises, on a page nobody told you about.
The six-month shift, measured
Take the most common single period end in the dataset, 2024-12-31 (703 records). That date sits in tax year 2024/25. Six months later is 30 June 2025, which sits in 2025/26. The income is reported on the 2025/26 return, a year after the period most people would file it against, and after the 2024/25 return has already gone in.
Done for every record in the set: 6,437 of 11,896 (54.1%) arise in a later tax year than the one their reporting period ended in, and 5,459 (45.9%) stay in the same one. The later year is the normal outcome.
Show all twelve months as a table
| Reporting period ends in | Records | Share | Income arises in |
|---|---|---|---|
| January | 1 | 0.0% | July |
| February | 573 | 4.8% | August |
| March | 1,393 | 11.7% | September |
| April | 12 | 0.1% | October |
| May | 1,449 | 12.2% | November |
| June | 1,112 | 9.3% | December |
| July | 294 | 2.5% | January |
| August | 2,419 | 20.3% | February |
| September | 173 | 1.5% | March |
| October | 652 | 5.5% | April |
| November | 355 | 3.0% | May |
| December | 3,463 | 29.1% | June |
The 5 April cliff
Because the tax year turns on 5 April, a period end in early October puts the fund distribution
date within days of the boundary. 171 records
(1.4%) have a fund distribution date between 26 March and 15 April, where
a few days' difference in the period end moves the entire charge into the other tax year. The period
ends responsible are 2018-09-28, 2019-09-29, 2025-09-30, all of them
late-September ends, six months from which lands on top of the line.
A fund that shifts its period end by two days, which is an administrative decision nobody announces to unitholders, moves that income between two returns.
What this means if you hold one of these funds
- The year to look at is the one containing period end + 6 months, not the one the period ended in. For 54.1% of these records those are different years.
- If you sold during the period, check whether you held at the period end. If you did, the charge is still yours (reg 94(3)). If you sold before the period end and bought back within 30 days, reg 94(3A) deems you to have held it anyway, because s106A TCGA 1992 matched the two.
- The figure and the charge can be the same day old. Reg 90(5) lets the fund publish on the fund distribution date itself, so "the number was not out yet" happens, and it does not remove the charge.
- The uplift matters as much as the income. The same excess also increases your Section 104 cost, which reduces the gain on every later disposal. Miss the income and you also overstate the gain, so one omission is taxed twice.
What this cannot tell you
- It does not say whether your fund is in the set. These are 2,755 share classes from 8 managers. The reporting fund list is much larger. A fund that is not here is not a fund with nil income.
- Reg 94(3) has an earlier alternative. The excess is treated as made on the fund distribution date "or on such earlier date as the reported income in respect of that reporting period is recognised in the participant's accounts". That is a taxpayer-specific fact, so every date on this page is the reg 94(4) date.
- It is not about whether the charge is dividend or interest. That turns on what the fund holds, which these records do not say. It changes the rate, not the date.
Method
The fund distribution date for each of the 11,896 records is the period end plus six calendar months, clamped to the last day of the target month where the day does not exist (reg 94(4)). It is the same arithmetic the calculator's engine uses. The tax year of a date is the year beginning 6 April. "Later tax year" compares the tax year of the fund distribution date with the tax year of the period end. Legislative text is quoted from legislation.gov.uk as at 2026-09-22.
96 distinct period-end dates appear, on 38 distinct
month-and-day combinations. Every figure in this prose is recomputed from the dataset by
test/research-pages.test.mjs.
Related: what the records themselves show, including how often the published figure is nil. To look up a fund, the ERI lookup.