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‘Umbrella funds� means arrangements which provide for separate pooling of the contributions of the participants and the profits or income out of which payments are made to them. References to a part of umbrella funds are to the arrangements relating to a separate pool (or ‘sub-fund�). See IFM12260 for details of how umbrella funds are treated in relation to the definition of an offshore fund.

For the purposes of the detailed rules set out in »Ê¹ÚÌåÓýapp Offshore Funds (Tax) Regulations where there are umbrella arrangements:

• any reference to the assets of an offshore fund or the income arising on those assets is a reference to the part of the assets of the main arrangements that relates to a particular separate pool (sub-fund); and
• any reference to participants in an offshore fund is to investors owning an interest in a particular separate pool (sub-fund).