Section 747E of the Principal Act is amended -

(a) in subsection (1) by substituting "Subject to subsection (1A), where on or after" for "Where on or after", and

(b) by inserting the following after subsection (1):

"(1A)

(a) In this subsection -

'umbrella scheme' means an offshore fund -

(i) which is divided into a number of sub-funds, and

(ii) in which each person who has a material interest in a sub-fund is entitled to exchange the whole or part of such interest for an interest in another sub-fund of the offshore fund.

(b) A disposal under subsection (1) does not include any exchange by a person who has a material interest in a sub-fund of an offshore fund which is an umbrella scheme, effected by way of a bargain made at arm's length by that offshore fund, of the whole or part of such interest for an interest in another sub-fund of that offshore fund.

(c) Any exchange referred to in paragraph (b) shall not be regarded as a disposal by a person of a material interest in an offshore fund which is an umbrella scheme.".