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The Offshore Funds (Tax) Regulations 2009
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6.—(1) This paragraph applies in the case of an existing fund which—
(a)makes a successful application under paragraph 3 to continue to be treated as a distributing fund after 1st December 2009, and
(b)becomes a reporting fund immediately following the end of the overlap period or the succeeding period.
(2) For the purposes of regulations 17 and 99 the fund is treated as a reporting fund for the entirety of a continuous period—
(a)beginning with the day the fund becomes a distributing fund, and
(b)ending on the last day of the overlap period or the succeeding period (as the case may be).
(3) If for any part of the period specified in sub-paragraph (2) the fund is not a distributing fund, the period is not continuous for the purposes of that sub-paragraph.
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