In early March, HM Treasury published an order under the Finance Act 2009 to provide that, from 1 April 2010, an interest in a relevant offshore fund will be treated for corporation tax on chargeable gains purposes as if the fund were a company and the interests of the corporate participants were shares in the company. A relevant offshore fund for this purpose is a fund that is neither a company nor a unit trust scheme. As partnerships are excluded from the definition of offshore funds, this legislation is directed at contractual common fund arrangements.