Last year’s UK Emergency Budget announced that, with effect from 23 June 2010, there would be two rates of capital gains tax (CGT): 18% for basic rate taxpayers, and 28% for higher and additional rate taxpayers. Whilst the increase in the rate of CGT for the highest earning UK individuals is significant, it is still substantially less than the rates of tax paid by such individuals on income. As a result it is still important for investment vehicles to offer tax-efficient CGT treatment to UK individual investors upon disposal of their investments (for example, so that the UK offshore fund rules do not apply).