For account periods ending before 22 July 2004, in respect of an offshore fund’s investments in trading companies, the 10 per cent limits in former ICTA 1988, s. 760(3)(b) and (c) were raised to 20 per cent and 50 per cent respectively. Thus, a fund could invest up to 20 per cent by value of its assets in a single trading company, and it could own up to 50 per cent of the issued share capital (or class thereof) of a particular trading company (former ICTA 1988, Sch. 27, para. 10).

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