These Regulations amend the Offshore Funds (Tax) Regulations 2009, which make provision for the tax treatment of participants in offshore funds, to clarify the application of regulation 17 (the charge to tax) where the interest in the offshore fund which is disposed of was acquired in consequence of an exchange or scheme of reconstruction to which section 135 or 136 of the Taxation of Chargeable Gains Tax Act 1992 applied.