SCHEDULES

SCHEDULE 28COMPUTATION OF OFFSHORE INCOME GAINS

PART IDISPOSALS OF INTERESTS IN NON-QUALIFYING FUNDS

The offshore income gain

5(1)Subject to sub-paragraph (2) below, a material disposal gives rise to an offshore income gain of an amount equal to the unindexed gain on that disposal.

(2)In any case where—

(a)paragraph 4 above applies, and

(b)the post-1983 gain on the material disposal is less than the unindexed gain on the disposal,

the offshore income gain to which the disposal gives rise is an amount equal to the post-1983 gain.