1. This statement sets out the Revenue's views on the interpretation of certain provisions of this legislation, on which queries have been raised.
Material interests in offshore funds
2. The legislation applies to “material interests” in offshore funds. For such an interest to exist, the investor, at the time of acquiring his investment, must have a reasonable expectation of being able to realise it within seven years for an amount reasonably approximate to that portion which the investment represents of the market value of the entity's underlying assets.