½Û×ÓÊÓƵ

Offshore fund

For these purposes an offshore fund means¹:

1. Ìý

   •ÌýÌýÌýÌý a mutual fund which is a body corporate (other than an LLP²) resident outside the UK

2. Ìý

   •ÌýÌýÌýÌý a mutual fund under which property is held on trust for the participants where the trustees are not resident in the UK

3. Ìý

   •ÌýÌýÌýÌý a mutual fund which is other arrangements that create, under foreign law, rights in the nature of co-ownership (other than a mutual fund which is two or more persons carrying on a trade or business in partnership³). The meaning of co-ownership is not restricted to its meaning in UK law⁴. It takes its meaning from the law of the territory in which the arrangements take effect⁵.

It should be noted that this meaning does not apply in the phrase 'material interest in an offshore fund'⁶.

Reference to participants in arrangements or a fund are to persons taking part in the arrangements (or the arrangements consisting the fund) whether