The Offshore Funds (Tax) Regulations 2009

Participants chargeable to corporation tax
This adran has no associated Memorandwm Esboniadol

98.—(1) This regulation applies if some or all of the excess specified in regulation 94 is treated as made to a participant chargeable to corporation tax.

(2) The amount is exempt if it would be exempt if it were an actual distribution made by the fund.