[378A Offshore fund distributions]
Income Tax (Trading and Other Income) Act 2005 (2005 c 5) | Legislation

[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 for income tax purposes.

(3)     For the purposes of this section, an offshore fund fails to meet the qualifying investments test if the market value of

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