Global Fund Prospectus - Jupiter Asset Management

THE JUPITER GLOBAL FUNDSupplementary Information for Investors in the United Kingdom■■Supplementary Information for Investors in the United Kingdomthe date the report is issued by the Directors provided that therelevant Class reports within 6 months of the accounting periodend. It is expected that the report will be available within 6months of the accounting period end. For accounting periods upto and including the period ending 30 September 2011, ‘reportingfund’ certification will be obtained in accordance with transitionalprovisions in the Regulations, which apply where a fund haspreviously been certified as a ‘distributing fund’ for UK taxpurposes. Shareholders in the relevant Classes during theseperiods will be taxed only on actual cash distributions received.The ‘total reportable income’ for those Classes which areclassified as Reporting Funds will be published online at: www.jupiteronline.com.e) Subject to paragraph (c) above, capital gains arising on adisposal of Shares by individuals will be liable to capital gains taxat either 18% or 28% if, together with other net gains, theyexceed the annual exemption, which is GBP 10,600 for the fiscalyear ending 5 April 2012. The applicable rate of capital gains taxfor other non-corporate investors is currently a flat rate of 18%.In the case of companies generally, gains arising on a disposalof Shares (after indexation allowance), will be liable to corporationtax. The mainstream rate of corporation tax is currently 28%.Tax rates may be different for subsequent financial years.f) Since the Company does not propose to seek certification fromHMRC as a Distributing Fund or as a Reporting Fund for allClasses in issue, any gains arising on a redemption, disposal (ordeemed disposal) or on conversion from one Class to another ofShares in a Class which is not specifically identified in therelevant Information Sheet as being a Distributing Fund or aReporting Fund will be ‘offshore income gains’ for tax purposesand will generally be liable to tax as income for Shareholderswho are resident or ordinarily resident in the UK for tax purposes.Gains chargeable to tax as income under the offshore fundsprovisions are not eligible for Capital Gains Tax annualexemption which is available annually for individuals or, in thecase of corporate Shareholders, an indexation allowance.g) Dividends received by Shareholders liable to UK income tax orreinvested on their behalf in further Shares, or reported income inexcess of the dividends received by Shareholders, received fromcorporate offshore funds which are largely invested in equities willbe charged to income tax as dividends from a non-UK residentcompany. These income receipts should be declared on theinvestor’s tax return and will be taxable at the applicable rate ofincome tax. The rates for the fiscal year ended 5 April 2012 is 10%where net income is less than GBP 35,000 and 32.5% or 42.5%for higher rate or additional rate tax payers respectively. IndividualShareholders resident or ordinarily resident in the UK will generallybenefit from a non-refundable tax credit in respect of suchdividends received from corporate offshore funds. The effect ofthis notional tax credit is that dividends will be deemed to bereceived net of a 10% withholding tax.h) It should be noted that, where 60% or more of the fund assets areinvested in interest-bearing products, individual Shareholdersresident or ordinarily resident in the UK receiving distributionsand/or reported income will be treated for UK tax purposes ashaving received interest income and not a dividend. This willmean that the applicable tax rates will be those for interest income(currently 20% basic rate, 40% higher rate and 50% for additionalrate tax payers respectively) and that no tax credit will apply.i) Individual Shareholders resident or ordinarily resident In the UKshould note the provisions of Chapter 2 of Part 13 of the IncomeTax Act 2007. These provisions are directed to the prevention ofavoidance of income tax through transactions resulting in thetransfer of assets or income to persons (including companies)resident or domiciled outside the UK and may render them liableto taxation in respect of any undistributed income and profits ofthe Fund on an annual basis. This legislation is not directedtowards the taxation of capital gains.j) The attention of investors resident or ordinarily resident in theUK (and who, if individuals. are also domiciled in the UK forthose purposes) is also drawn to the provisions of Section 13 ofTaxation of Chargeable Gains Act 1992 (‘Section 13’). Underthese provisions, where a chargeable gain accrues to a companythat is not resident in the UK, but which would be a closecompany if it were resident in the UK, a person may be treatedas though a proportional part of that chargeable gain, calculatedby reference to their interest in the company, has accrued tothem. No liability under Section 13 can be incurred by such aperson, however, where such proportion does not exceed onetenthof the gain.k) Dividends received by Shareholders subject to UK corporationtax or reinvested on their behalf in further Shares, will be treatedas income receipts. For Shareholders subject to UK corporationtax most forms of overseas dividends will be exempt from thecharge to UK corporation tax provided they fall within one of theexempt classes of distributions listed in Part 9A of the CorporationTax Act 2009.l) The attention of corporate Shareholders is drawn to Chapter 3 ofPart 6 of the Corporation Tax Act 2009, whereby relevant interestsof companies in offshore funds may be deemed to constitute aloan relationship with the consequence that all profits and losseson such relevant interests are chargeable to corporation tax inaccordance with a fair value basis of accounting. The relevantprovisions apply where the market value of interest bearingsecuritiesand other qualifying investments of a fund comprisesmore than 60% of the value of all the investments of that fund atany time during an accounting period.m) Corporate Shareholders resident in the UK should note theprovisions of Chapter 4 of Part 17 of the Taxes Act. Theseprovisions may subject UK resident companies to corporationtax on profits of non-resident companies. controlled by personsresident in the UK, in which they have an interest. Theseprovisions affect UK resident companies who have an interest ofat least 25% in the profits of a non-resident company, whichdoes not distribute substantially all its income. In view of theproposed income distribution policy, it is not anticipated thatthese provisions will have any material effect on UK residentcorporate Shareholders. This legislation is not directed towardsthe taxation of capital gains.n) Investors who are insurance companies within the charge toUnited Kingdom corporation taxation holding their Shares in theFund for the purposes of their long-term business (other thanpension business) will be deemed to dispose of and immediatelyreacquire those Shares at the end of each accounting period.38