The Unit Trust Schemes and Offshore Funds (Non-qualifying Investments Test) Order 1997
Paragraph 4 of Schedule 10 to the Finance Act 1996 (“Schedule 10”) makes provision relating to the taxation of a company’s loan relationships in cases where the company holds rights under a unit trust scheme or any relevant interest in an offshore fund in an accounting period and the scheme or fund fails to satisfy “the non-qualifying investments test” at any time in that period.