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.