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The Offshore Funds (Tax) Regulations 2009

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Application of section 128 of TCGA 1992U.K.

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47.—(1) This regulation applies if there is a disposal to which this Part applies by virtue of—

[F1(aa)regulation 36A (exchanges and schemes of reconstruction), or]

(c)regulation 37 (exchange of interests of different classes).

(2) TCGA 1992 has effect as if an amount equal to the offshore income gain to which that disposal gives rise were given (by the person making the exchange) as consideration for the new holding (within the meaning of section 128 of that Act (consideration given or received for new holding on a reorganisation)).

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