SCHEDULES

SCHEDULE 10U.K. Loan relationships: collective investment schemes

Distributing offshore fundsU.K.

3For the purposes of paragraph 5(1) of Schedule 27 to the Taxes Act 1988 (computation of UK equivalent profit), the assumptions to be made in determining what, for any period, would be the total profits of an offshore fund are to include an assumption that paragraph 2 above applies in the case of that offshore fund as it applies in the case of any authorised unit trust.