(1) In this section 'scheme of reconstruction or amalgamation' means an arrangement under which each person who has a material interest in an offshore fund (in this section referred to as an 'old interest') receives in place of that old interest a material interest in another offshore fund (in this section referred to as the 'new interest') in respect of or in proportion to, or as nearly as may be in proportion to, the value of the old interest and as a result of which the value of that old interest becomes negligible.

(2) Where, in connection with a scheme of reconstruction or amalgamation, a person disposes of an old interest and receives in place of that old interest a new interest, the disposal of the old interest shall not give rise to a gain but the new interest shall for the purposes of section 747E(2) be treated as acquired at the same time and at the same cost as the old interest.