Pass-through taxation preserves investor-level tax treatment of investment fund income while ring-fencing fund-level losses.
Clause 224 restates a pass-through regime: income from investments in a regulated fund is taxed in the hands of unit holders as if held directly, while business income remains taxable at the fund level. Business losses are ring fenced at the fund; other losses pass through subject to holding period conditions and transitional attribution of legacy losses to unit holders. Income retained by the fund is deemed credited to unit holders at year end and prescribed statements must be furnished to unit holders and tax authorities to secure transparency and enforcement.