PART 2THE TREATMENT OF PARTICIPANTS IN NON-REPORTING FUNDS
CHAPTER 3EXCEPTIONS ETC. FROM THE CHARGE TO TAX
F1Unlisted trading company exception: further provision31C
No liability to tax arises under regulation 17 if—
a
the disposal is of an interest in an offshore fund whose business consists solely of holding an interest in another offshore fund (“X”), and
b
conditions B to D of regulation 31A apply in relation to X.