The Unit Trust Schemes and Offshore Funds (Non-qualifying Investments Test) Order 2006
Paragraph 4 of Schedule 10 to the Finance Act 1996 (c. 8) (“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 during an accounting period, and the scheme or fund fails to satisfy the non-qualifying investments test at any time in that period.