{
  "url": "https://openlegislation.uk/offshore-funds-tax-regulations-2009/regulation-37",
  "json_url": "https://openlegislation.uk/offshore-funds-tax-regulations-2009/regulation-37.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/37",
  "kind": "regulation",
  "number": "37",
  "heading": "Exchange of interests of different classes",
  "text": "(1) If conditions A to D are met, section 127 of TCGA 1992 (equation of original shares and new holding) does not prevent an exchange from constituting a disposal for the purposes of these Regulations.\n(2) Condition A is that an offshore fund is constituted by a class of interest (“class A”) in main arrangements.\n(3) Condition B is that a participant exchanges an interest of class A for an interest in another offshore fund constituted by a different class of interest (“class B”) in those main arrangements.\n(4) Condition C is that the interest of class A is at the time of the exchange an interest in a non-reporting fund.\n(5) Condition D is that the interest of class B is at the time of the exchange an interest which is not an interest in a non-reporting fund.\n(6) Any disposal to which this regulation applies is to be treated as a disposal for a consideration equal to the market value of the rights at the time of the exchange.",
  "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/37",
    "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."
}