Paragraph 9

United Kingdom

(1)

The references in paragraphs 7 and 8(1) above to the primary fund’s share of—

(a)

an interest forming part of the assets of the qualifying fund, or

(b)

the excess income (as defined in paragraph 8 above) of the qualifying fund,

shall be construed as references to the fraction specified in sub-paragraph (2) below of that interest or excess income.

(2)

In relation to any account period of the primary fund, the fraction referred to in sub-paragraph (1) above is—

\frac{C}{D}

where—
C is the average value of the primary fund’s holding of interests in the qualifying fund during that period; and
D is the average value of all the interests in the qualifying fund held by any persons during that period.

Notes on Schedule 27

F1: Sch. 27 repealed (1.12.2009 with effect in accordance with reg. 1(2) of the repealing S.I.) by The Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001), regs. 1(1), 13(2)(3), Sch. 2 (with saving in Sch. 1 para. 3(4)) (subject, as saved, to modification by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 9 para. 24)