Related Commentary  

17(1)  There is a charge to tax if–

(a)a person disposes of an asset,

(b)either condition A or condition B is met, and

(c)as a result of the disposal, an offshore income gain arises to the person making the disposal.

17(2)  Condition A is that the asset is an interest in a non-reporting fund at the time of the disposal.

17(3)  Condition B is that–

(a)the asset is an interest in a reporting fund at the time of the disposal,

(b)the reporting fund was previously a non-reporting fund (becoming a reporting fund as the result of an application under regulation 52),

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