Exclusion of investments in distributing offshore funds
(1) In this Part of this Schedule, an offshore fund within subparagraph (2)(c) is referred to as a "qualifying fund".
(2) In any case where -
(a) in an account period of an offshore fund (in this Part of this Schedule referred to as "the primary fund"), the assets of the fund consist of or include interests in another offshore fund,
(b) those interests (together with other interests which the primary fund may have) are such that, by virtue of paragraph (a) of subsection (3) of section 744 or, if the other fund concerned is a company, paragraph (b) or (c) of that subsection, the primary fund could not apart from this paragraph be certified as a distributing fund in respect of the account period, and
(c) without regard to this paragraph, that other fund could be certified as a distributing fund in respect of its account period or, as the case may be, each of its account periods which comprises the whole or any part o
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