Where there is a difference between a fund's reportable income for a period of account and the income reported by that fund for all reporting periods comprised in the period of account, the nature of the breach and the action to be taken depends on the relative size of the difference, as follows (the Offshore Funds (Tax) Regulations 2009 (SI 2009/3001), reg. 110):

(1)where the difference between the reported income for a reporting period and the reportable income for the period of account referrable to that reporting period is less than 10 per cent of the reportable income, there is no breach.

(2)where the difference is more than 10 per cent but less than 15 per cent, the fund must:

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