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Taxation (International and Other Provisions) Act 2010

Section 360: Treatment of umbrella arrangements

656.This section sets out the treatment of umbrella arrangements (as defined in section 363). It is based on section 40A(1) and 40C(1) of FA 2008.

657.Subsection (2) provides that where there are such arrangements, each separate part (usually known as a “sub-fund”) is to be treated as a separate arrangement and the overall arrangements are disregarded. In such a case the overall arrangements themselves do not constitute a mutual fund or an offshore fund.

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