Clearance can be sought that a fund meets the equivalence and the genuine diversity of ownership conditions (the Offshore Funds (Tax) Regulations 2009 (SI 2009/3001), reg. 77–79). An application can be made by:

the manager of an eligible offshore fund (being an offshore fund which is not a guaranteed return fund; see ¶783-300);

the manager of a non-reporting fund who makes an application under reg. 52 (meaning that the fund must never have been a reporting fund except where it ceased to be a reporting fund because it gave notice under reg. 116; see ¶783-300); or

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