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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: close companies

IFM40620 | Other tax issues: close companies

From HM Revenue & Customs · Investment Funds Manual

FA22/SCH2/PARA37

Many QAHCs will be close companies on general principles. However, special provision is made in PARA 37 to apply the loans to participators and related rules to all QAHCs even when they are not close.

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