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Contents

Official guidance
Investment Funds Manual

IFM40600 · Other tax issues

  • IFM40610 · Introduction
  • IFM40620 · Close companies
  • IFM40630 · Exchange gains
  • IFM40640 · Amortised cost basis of accounting
  • IFM40650 · Transfer pricing: introduction and legislative changes
  • IFM40660 · Transfer pricing: accurate delineation
  • IFM40670 · Transfer pricing: pricing
  • IFM40680 · Corporate interest restriction: non-consolidation of certain subsidiaries
  • IFM40690 · Corporation interest restriction: consolidation of QAHC stacks
  • IFM40695 · Whether investments are non-commercial securities
  1. Other tax issues: contents
  2. Other tax issues: introduction

IFM40610 | Other tax issues: introduction

From HM Revenue & Customs · Investment Funds Manual

In the specific context of a QAHC, various rules in the Taxes Acts would result in an unintentional tax treatment without modification. Such rules have, therefore, been amended for companies that are eligible and choose to join the QAHC regime to ensure they give the desired result.

The following pages explain how certain rules are amended for the QAHC regime covering:

  • Close companies (IFM40620);

  • Exchange gains (IFM40630);

  • Amortised cost basis of accounting (IFM40640);

  • Transfer pricing (IFM40650+);

  • Corporate Interest Restriction (IFM40680+).

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