Section 259NDA | Meaning of “qualifying institutional investor” etc
From legislation.gov.uk
(1)This section has effect for the purposes of this Part.
(2)References to “qualifying institutional investor” have the meaning given by paragraph 30A of Schedule 7AC to TCGA 1992.
(3)A qualifying institutional investor is “based” in a territory—
(a)if it is resident for tax purposes in the territory, or
(b)where it is not resident anywhere for tax purposes, if it is established in the territory.