Corporation Tax Act 2009 section 489

Meaning of "offshore fund" etc.

Section 489 defines what is meant by "offshore fund" and related terms for the purposes of the chapter on loan relationships involving offshore funds.

• The definition of "offshore fund" is imported from sections 355 to 363 of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010).
• Those TIOPA 2010 provisions also cover how the rules apply to parts of umbrella funds and to different classes of interests in offshore funds.
• The same definitions and rules that apply for Part 8 of TIOPA 2010 (which deals with the offshore funds tax regime) apply equally for this chapter of CTA 2009.
• This ensures a consistent meaning of "offshore fund" is used across both the loan relationships rules and the wider offshore funds legislation.