Taxation (International and Other Provisions) Act 2010 section 361

Treatment of arrangements comprising more than one class of interest

Section 361 explains how arrangements that have more than one class of interest are treated for the purposes of this Part of the Act.

• Where arrangements contain more than one class of interest, each class must be treated as a separate set of arrangements in its own right.
• The overall "main arrangements" are disregarded once they have been split into their separate classes of interest.
• Each class of arrangements is assessed independently when determining whether the arrangements constitute a mutual fund.
• For umbrella arrangements, a "class of interest" does not include a sub-part of the umbrella itself, although a single sub-part of umbrella arrangements may contain more than one class of interest.