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Contents

Official guidance
Investment Funds Manual

IFM40100 · Overview

  • IFM40110 · Introduction
  • IFM40120 · Policy Background
  • IFM40130 · A short guide
  • IFM40140 · Structure of the legislation
  1. Overview: contents
  2. Overview: structure of the legislation

IFM40140 | Overview: structure of the legislation

From HM Revenue & Customs · Investment Funds Manual

The rules for qualifying asset holding companies (QAHCs) are contained within FA22/SCH2.

The legislation is structured as follows:

PartProvisionIFM guidance pages
1Conditions that must be met for a company to be a QAHCIFM40200+
2How a company becomes a QAHC and the consequencesIFM40300+
3How a company ceases to be a QAHC and the consequencesIFM40400+
4Groups of companies that include QAHCsIFM40500+
5Application of certain tax rules: close companies, exchange gains, basis of accountingIFM40600+
6Application of other tax rules: transfer pricing, corporate interest restrictionIFM40650+
7aTreatment of certain amounts payable by a QAHC: distribution rulesIFM40720
7bTreatment of certain amounts payable by a QAHC: hybrid and other mismatch rulesIFM40730
7cTreatment of certain amounts payable by a QAHC: remittance basisIFM41000+
7dTreatment of certain amounts payable by a QAHC: purchase of own sharesIFM40740
7eTreatment of certain amounts payable by a QAHC: transactions in securitiesIFM40750
7fTreatment of certain amounts payable by a QAHC: late interestIFM40760
7gTreatment of certain amounts payable by a QAHC: deeply discounted securitiesIFM40770
8Overseas property business of a QAHCIFM40800+
9Chargeable gains exemption on the disposals of overseas land and certain sharesIFM40900+
10Exemption from stamp duty and stamp duty reserve tax on the repurchase by an QAHC of its own shares or loan capitalIFM41100+
11Withholding tax exemptionIFM40780
12Meaning of terms used
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