Taxation (International and Other Provisions) Act 2010 section Sch 9 para 24

Offshore fund treated after 1 December 2009 as distributing fund under repealed Chapter 5 of Part 17 of ICTA

Schedule 9 paragraph 24 ensures that a cross-reference used in the old distributing fund rules for offshore funds continues to work correctly after the rewrite of tax legislation.

• This provision deals with offshore funds that were treated as "distributing funds" under the old ICTA rules, which were preserved in a transitional form by the Offshore Funds (Tax) Regulations 2009.
• Under the old Schedule 27 to ICTA, paragraph 5(4)(b) referred to section 811 of ICTA, which allowed a deduction from income for foreign tax paid, as an alternative to claiming a credit against UK tax.
• Since the ICTA provisions have been rewritten, this paragraph redirects that old reference so that it now points to section 112 of the Taxation (International and Other Provisions) Act 2010, which is the equivalent replacement provision.
• The effect is purely mechanical: it keeps the transitional distributing fund rules functioning as intended, without any change in substance, by updating the statutory cross-reference to the new legislation.