Offshore funds distributing to the UK must begin to consider the impact of the new UK tax reporting regime. The regime aims to deliver increased certainty for UK investors and fund managers and reduce the compliance burden associated with distributor status. Does it deliver on its promises? Increased flexibility regarding cash distributions, investment strategies and reporting formats is tempered by continuing uncertainty about the scope of the regime, complex issues associated with the calculation of reportable income and strict breach provisions. Continued consultation between HMRC and industry will be imperative to ensure the new regime evolves into a workable and positive development for the industry and UK investors.