Significant changes to the rules applying with regard to funds which operate equalisation arrangements were made to the Offshore Funds (Tax) Regulations 2009 (SI 2009/3001) by the Offshore Funds (Tax) (Amendment) Regulations 2011 (SI 2011/1211) (the ‘amending regulations’). The amending regulations apply with effect for distributions and disposals made on or after 27 May 2011 (SI 2011/1211, reg. 1(2)). However, provision is made for their retrospective application in some cases (SI 2011/1211, reg. 14–17). Commentary on the rules providing for the treatment of funds which operate equalisation arrangements can be found below. See also:

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