{
  "url": "https://openlegislation.uk/offshore-funds-tax-regulations-2009/regulation-25",
  "json_url": "https://openlegislation.uk/offshore-funds-tax-regulations-2009/regulation-25.json",
  "legislation": "uksi/2009/3001",
  "legislation_title": "The Offshore Funds (Tax) Regulations 2009",
  "legislation_url": "https://openlegislation.uk/offshore-funds-tax-regulations-2009",
  "path": "regulation/25",
  "kind": "regulation",
  "number": "25",
  "heading": "Exceptions from the charge",
  "text": "(1) No liability to tax arises under regulation 17 if any of conditions A to E is met.\n(2) Condition A is that the participant is required to treat the interest in the fund as a loan relationship under Chapter 3 of Part 6 of CTA 2009.\n(3) Condition B is that the participant is required to treat the interest in the fund as a derivative contract to which the provisions of Part 7 of CTA 2009 apply.\n(4) Condition C is that the asset is an intangible fixed asset to which the provisions of Part 8 of CTA 2009 apply.\n(5) Condition D is that the asset consists of excluded indexed securities as defined in section 433 of ITTOIA 2005.\n(6) Condition E is that the asset is a right arising under a policy of insurance.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2009/3001/regulation/25",
    "retrieved_at": "2026-10-29T03:01:48.652414+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}