(1) For the purposes of this Chapter, an offshore fund operates equalisation arrangements if and at a time when arrangements are in existence which have the result that where -
(a) a person acquires by means of initial purchase a material interest in the fund at some time during a period relevant to the arrangements, and
(b) the fund makes a distribution for a period which begins before the date of the acquisition of that interest,
the amount of that distribution paid to the person (assuming the person is still retaining that interest) will include a payment of capital debited to an account (in this Chapter and in Schedules 19 and 20 referred to as "the equalisation account") maintained under the arrangements and determined by reference to the income which had accrued to the fund at the date of the person's acquisition.
(2) For the purposes of this section, a person shall acquire an interest in an offshore fund by means of initial purchase if the person's acquisition is by -
(a) subscr
…