SCHEDULE 1U.K.Transitional Provisions and Savings

5.—(1) This paragraph applies in the case of an existing fund which—U.K.

(a)immediately before 1st December 2009 was a non-qualifying fund, and

(b)on 1st December 2009 becomes a reporting fund.

(2) Regulation 48 applies as if, for references to the non-reporting fund, there were substituted references to the existing fund.

(3) Chapter 5 of Part 17 of ICTA applies to determine the offshore income gain arising by virtue of the application of regulation 48.