IFM12282 - Offshore Funds: Definition of an offshore fund: particular arrangements: Exchange Traded Funds
Exchange traded funds are usually operated in such a way that the quoted prices are at net asset value (鈥楴AV鈥�) or very close to NAV, and so would be expected to meet the characteristics set out in the legislation and to come within the meaning of a mutual fund, and therefore within the definition of an offshore fund.
As with other classes of interest, it is important to note that fungible shares can only constitute a single class of interest even if different types of holders of those shares enjoy different rights (see IFM12270 - Classes of interest).