Related Commentary  Related HMRC Manuals

354(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.

354(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), or

(b)arrangements relating to a class of interest in other arrangements (see section 361).

354(3)  Regulations under subsection (1) may, in particular–

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