IFM40910 | Gains exemption: introduction

FA22/SCH2/PT9

Qualifying asset holding companies (QAHCs) are exempt from corporation tax on chargeable gains realised on the disposal of certain assets. A QAHC cannot choose to disapply this exemption.

The gains exemption is limited to those asset classes specified at FA22/SCH2/PARA53 and these asset classes are within the QAHC ring fence (IFM40350).

Correspondingly, any losses arising on disposal of these asset classes are unallowable.

Where a deemed market value disposal is made by a QAHC of its ring fence assets on departure from the regime at FA22/SCH2/PARA32, that disposal falls within the gains exemption. As a result, any loss or gain on a ring fence asset accrued during the QAHC’s time in the regime falls outside the scope of tax.