39 Certain distributions of offshore funds taxed as interest
Finance Act 2009 (2009 c 10) | Legislation

39  Certain distributions of offshore funds taxed as interest

(1)     Chapter 2 of Part 4 of ITTOIA 2005 (interest) is amended as follows.

(2)     In section 369(2) (list of provisions extending what is treated as interest for certain purposes), after the entry relating to section 376 insert—

“section 378A (offshore fund distributions),”.

(3)     After section 378 insert—

“378A Offshore fund distributions

(1)     This section applies where—

(a)     a dividend is paid by an offshore fund, and

(b)     the offshore fund fails to meet the qualifying investments test at any time in the relevant period.

(2)     The dividend is treated as interest

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