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The Offshore Funds (Tax) (Amendment) Regulations 2011
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Insertion of new regulation 50A (meaning of “equalisation arrangements”, “full equalisation arrangements” and “equalisation amount”)
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5. After regulation 50 insert—
“Meaning of “equalisation arrangements”, “full equalisation arrangements” and “equalisation amount”
50A. For the purposes of this Part—
(a)a reporting fund operates equalisation arrangements if it has given a statement under regulation 53(1)(h) that it intends to operate such arrangements;
(b)a reporting fund operates full equalisation arrangements if in relation to any interest acquired by way of initial purchase in the reporting period—
(i)the equalisation amount included in the consideration for the purchase is specified by the fund in a statement in writing to the participant making the acquisition, or
(ii)the equalisation amount per unit of interest in the fund is included in the report made available in accordance with regulation 90;
(c)“equalisation amount” has the meaning given in regulation 72(2).”.
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