Taxation (International and Other Provisions) Act 2010 section 259NA

Meaning of "relevant investment fund"

Section 259NA defines what counts as a "relevant investment fund" for the purposes of the hybrid mismatch rules, specifying three types of fund that qualify provided they meet a genuine diversity of ownership condition.

  • A relevant investment fund can be an open-ended investment company (OEIC), an authorised unit trust, or an offshore fund
  • Whichever type of fund it is, it must meet the genuine diversity of ownership condition to qualify
  • For offshore funds, the diversity of ownership test is set out in regulation 75 of the Offshore Funds (Tax) Regulations 2009
  • For OEICs and authorised unit trusts, the test is in regulation 9A of the Authorised Investment Funds (Tax) Regulations 2006

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