There will be a disposal for the purposes of the Offshore Funds (Tax) Regulations 2009 (SI 2009/3001) if there would be a disposal for the purposes of the TCGA 1992 (the Offshore Funds (Tax) Regulations 2009 (SI 2009/3001), reg. 33; see ¶514-000 for commentary on the meaning of disposal for capital gains purposes). This is subject to the following four exceptions, the first applying where an investor dies and the remainder applying where an interest in a non-reporting fund is exchanged for an interest in an entity which is not a non-reporting fund and where the exchange would not give rise to a disposal under the Taxation of Chargeable Gains Act 1992:

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