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Home / Simons-Taxes /Corporate tax /Part D8 Investment schemes /Division D8.1 Collective investment schemes /Funds investing in non-reporting offshore funds / D8.151 Qualifying conditions
Commentary

D8.151 Qualifying conditions

Corporate tax

The provisions apply automatically to an authorised investment fund which1:

  1. Ìý

    (a)ÌýÌýÌýÌý meets the investment condition (ie the total amount invested in non-reporting funds or other FINROFs is, from 6 March 2011, more than 50% (20% prior to this date)2 of the gross asset value of the authorised investment fund (excluding cash awaiting investment)). Non-reporting funds do not include interests in offshore funds that are exempt from a charge to tax on disposal by virtue of SI 2009/3001, regs 29, 30 or any interest of an AIF in a non-reporting fund which meets the conditions of SI 2006/964, reg 14ZA (see B5.706)3. Prior to 6 March 2011 interests in any offshore fund that are treated as creditor relationships under CTA 2009, s 490 were also excluded

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