The Offshore Funds (Tax) Regulations 2009 (SI 2009/3001), Pt. 3, Ch. 6 applies to treat capital profits, gains and losses arising from an investment transaction entered into by a reporting fund which meets the equivalence and genuine diversity of ownership conditions as non-trading (reg. 80; see also ¶783-400). The meaning of ‘investment transaction’ for this purpose is provided by reg. 81, supported by reg. 82–89.

Meaning of an ‘investment transaction’

For the purposes of SI 2009/3001, Pt. 3, Ch. 6, an ‘investment transaction’ is (reg. 81):

(1)any transaction in stocks and shares;

(2)any transaction in a relevant contract (see ¶783-450);

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