IFM12156 - Offshore Funds: Introduction: Overview of the offshore fund rules: classes of interest

Where there is more than one class of interest in arrangements (for example, a company or sub-fund with different share classes that each carries different rights), then each class of interest is treated as a separate fund. See IFM12270 for details of how separate classes of interest are treated in relation to the definition of an offshore fund.

For the purposes of the detailed rules set out in the Offshore Funds (Tax) Regulations where there are separate classes of interest:

• any reference to the assets of an offshore fund is a reference to the assets of the main arrangements or to the part of the assets of the main arrangements that relate to a particular class of interest;
• any reference to the income of an offshore fund is a reference to the income of the main fund that is attributable to a particular class of interest or to the income arising to the part of the assets of the main arrangements that relate to a particular class of interest; and
• any reference to participants in an offshore fund is to investors owning an interest in a particular class of interest.