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HMRC internal manual

Offshore Funds Manual

From
HM Revenue & Customs
Updated
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The 2009 offshore funds regime: introduction: umbrella funds

‘Umbrella arrangements’ means arrangements which provide for separate pooling of the contributions of the participants and the profits or income out of which payments are made to them. References to a part of umbrella arrangements are to the arrangements relating to a separate pool (or ‘sub-fund’). See OFM08000 for details of how umbrella funds are treated in relation to the definition of an offshore fund.

For the purposes of the detailed rules set out in the regulations, and for this guidance, where there are umbrella arrangements, then-

  • any reference to the assets of an offshore fund or the income arising on those assets is a reference to the part of the assets of the main arrangements that relate to a particular separate pool (sub-fund); and
  • any reference to participants in an offshore fund is to investors owning an interest in a particular separate pool (sub-fund).