Requirements as to distributions
(1) For the purposes of Chapter 2 of Part 27, an offshore fund pursues a full distribution policy with respect to an account period if -
(a) a distribution is made for the account period or for some other period which in whole or in part falls within that account period,
(b) subject to Part 2 of this Schedule, the amount of the distribution which is paid to the holders of material and other interests in the fund -
(i) represents at least 85 per cent of the income of the fund for the period, and
(ii) is not less than 85 per cent of the fund's Irish equivalent profits for the period,
(c) the distribution is made during the account period or not more than 6 months after the expiry of that period, and
(d) the form of the distribution is such that, if any sum forming part of it were received in the State by a person resident in the State and did not form part of the profits of a trade, profession or vocation, that sum would be chargeable to t
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