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HMRC internal manual

Offshore Funds Manual

Particular arrangements: limited life companies: overseas corporate law

Under some overseas corporate law, some companies must liquidate under certain circumstances within a particular time frame. Provided that none of the characteristics set out in the legislation and referred to in this guidance are met, this will not, on its own, mean that such arrangements will be within the definition of a mutual fund, and therefore an offshore fund, for UK tax purposes.