PART 2THE TREATMENT OF PARTICIPANTS IN NON-REPORTING FUNDS

CHAPTER 3EXCEPTIONS ETC. FROM THE CHARGE TO TAX

Loans other than participating loans28

1

No liability to tax arises under regulation 17 if the asset is a loan which is not a participating loan.

2

For the purposes of paragraph (1) a “participating loan” means a loan where the amount payable on redemption exceeds the issue price by an amount which is determined in whole or in part by reference to the income of the non-reporting fund.