354 Power to make regulations about tax treatment of participants

Part 8 Offshore Funds [etc]

Tax treatment of participants in offshore funds

354  Power to make regulations about tax treatment of participants

(1)     The Treasury may by regulations make provision about the treatment of participants in an offshore fund for the purposes of enactments relating to income tax, corporation tax or capital gains tax.

(2)     Regulations under subsection (1) may, in particular, make special provision about the treatment of participants in an offshore fund comprising—

(a)     a part of umbrella arrangements (see section 360),

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