# The Offshore Funds (Tax) Regulations 2009, Regulation 28: Loans other than participating loans


(1) No liability to tax arises under regulation 17 if the asset is a loan which is not a participating loan.
(2) For the purposes of paragraph (1) a “participating loan” means a loan where the amount payable on redemption exceeds the issue price by an amount which is determined in whole or in part by reference to the income of the non-reporting fund.

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Source: https://www.legislation.gov.uk/uksi/2009/3001/regulation/28 (the official version)
Page: https://openlegislation.uk/offshore-funds-tax-regulations-2009/regulation-28
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.