IFM40710 | Treatment of certain payments: introduction

There are various rules throughout the Taxes Acts which explain how certain payments are treated for taxation purposes. These govern when payments should be relieved and how they should be relieved.

Some of these rules have been amended for qualifying asset holding companies (QAHCs) to ensure that the regime works as intended. Certain distribution rules, for example, have been disapplied to ensure income that arises in the QAHC can be matched with a corresponding expense when it is passed back to investors (IFM40720).

The following pages explain how various other rules have been amended in the context of a QAHC:

• Distributions (IFM40720)

• Hybrid and other mismatch rules (IFM40730)

• Purchase of own shares (IFM40740)

• Transactions in securities (IFM40750)

• Late interest (IFM40760)

• Deeply discounted securities (IFM40770)

• Withholding tax (IFM40780)

• Remittance basis (IFM41000)