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HMRC internal manual

Offshore Funds Manual

Transitional rules: reporting fund previously not within definition of an offshore fund - Schedule 1 para (7)

A fund that was not an offshore fund within the definition in Chapter 5 of Part 17 of ICTA prior to 1 December but is within the definition in section 355 TIOPA 2010 applying to holdings acquired on or after 1 December 2009 could have applied for reporting fund status in relation to a period of account that is current on 1 December 2009 (note this only applies to funds that were not previously within the ICTA definition - so funds that were within the ICTA definition were only able to apply for reporting fund status from the beginning of the first period of account commencing on or after 1 December 2009 and not for periods that were current as at 1 December 2009).