The Offshore Funds (Tax) Regulations 2009

Loans other than participating loansU.K.

This section has no associated Explanatory Memorandum

28.—(1) No liability to tax arises under regulation 17 if the asset is a loan which is not a participating loan.

(2) For the purposes of paragraph (1) a “participating loan” means a loan where the amount payable on redemption exceeds the issue price by an amount which is determined in whole or in part by reference to the income of the non-reporting fund.